claim preclusion doctrine (Idaho) · Go Syfert
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claim preclusion doctrine in Idaho

10 Idaho opinions name it 2 courts 1985–2025 6 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Taylor v. Sturgellgreen
scotus · 2008 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015Stilwyn argues that such conclusion rests on a misunderstanding concerning the doctrine of claim preclusion — that the doctrine applies to prevent a party who declined to assert any counterclaims in prior litigation from later asserting those claims in a separate action. 4 “The preclusive effect of a federal-court judgment is determined by federal common law.” Taylor v. Sturgell, 553 U.S. 880, 891 , 128 S.Ct. 2161, 2170-71 , 171 L.Ed.2d 155, 167 (2008).

2015Stilwyn argues that such conclusion rests on a misunderstanding concerning the doctrine of claim preclusion — that the doctrine applies to prevent a party who declined to assert any counterclaims in prior litigation from later asserting those claims in a separate action. 4 “The preclusive effect of a federal-court judgment is determined by federal common law.” Taylor v. Sturgell, 553 U.S. 880, 891 , 128 S.Ct. 2161, 2170-71 , 171 L.Ed.2d 155, 167 (2008).

11
Von Puckett v. City of Emmettgreen
idaho · 1987 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See also Puckett v. City of Emmett, 113 Idaho 639, 642 , 747 P.2d 48, 51 (1987) (“Federal law determines the effects under the rules of res judicata of a judgment of a federal court.”) (quoting Restatement (Second) of Judgments § 87 (1982)).

2015See also Puckett v. City of Emmett, 113 Idaho 639, 642 , 747 P.2d 48, 51 (1987) (“Federal law determines the effects under the rules of res judicata of a judgment of a federal court.”) (quoting Restatement (Second) of Judgments § 87 (1982)).

11
Farmers National Bank v. Shireygreen
idaho · 1994 · cited in 1 Idaho opinions naming this issue, 2007–2007
2 sentences

2007Hindmarsh, 138 Idaho at 94 , 57 P.3d at 805 ; Farmers Nat’l Bank v. Shirey, 126 Idaho 63, 68 , 878 P.2d 762, 767 (1994).

2007Hindmarsh, 138 Idaho at 94 , 57 P.3d at 805 ; Farmers Nat’l Bank v. Shirey, 126 Idaho 63, 68 , 878 P.2d 762, 767 (1994).

11
Blackburn v. Olsongreen
idaho · 1949 · cited in 1 Idaho opinions naming this issue, 1990–1990
2 sentences

1990Blackburn v. Olson, 69 Idaho 428, 433 , 207 P.2d 1160, 1163-64 (1949); Pence v. Idaho State Horse Racing Comm’n, 109 Idaho 112, 115 , 705 P.2d 1067, 1070 (Ct.App.1985).

1990Blackburn v. Olson, 69 Idaho 428, 433 , 207 P.2d 1160, 1163-64 (1949); Pence v. Idaho State Horse Racing Comm’n, 109 Idaho 112, 115 , 705 P.2d 1067, 1070 (Ct.App.1985).

11
Pence v. Idaho State Horse Racing Commissiongreen
idahoctapp · 1985 · cited in 1 Idaho opinions naming this issue, 1990–1990
2 sentences

1990Blackburn v. Olson, 69 Idaho 428, 433 , 207 P.2d 1160, 1163-64 (1949); Pence v. Idaho State Horse Racing Comm’n, 109 Idaho 112, 115 , 705 P.2d 1067, 1070 (Ct.App.1985).

1990Blackburn v. Olson, 69 Idaho 428, 433 , 207 P.2d 1160, 1163-64 (1949); Pence v. Idaho State Horse Racing Comm’n, 109 Idaho 112, 115 , 705 P.2d 1067, 1070 (Ct.App.1985).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Berkshire Investments, LLC v. Taylor green
idaho · 2012
2 sentences

2025A claim preclusion defense has three elements: Under this doctrine, a claim is also precluded if it could have been brought in the previous action, regardless of whether it was actually brought, where: (1) the original action ended in final judgment on the merits, (2) the present claim involves the same parties as the original transaction, and (3) the present claim arises out of the same transaction or series of transactions as the original action. 6 Id.

2025A claim preclusion defense has three elements: Under this doctrine, a claim is also precluded if it could have been brought in the previous action, regardless of whether it was actually brought, where: (1) the original action ended in final judgment on the merits, (2) the present claim involves the same parties as the original transaction, and (3) the present claim arises out of the same transaction or series of transactions as the original action. 6 Id.

42024–2025
Ticor Title Co. v. Stanion green
idaho · 2007
2 sentences

2023Instead, the district court found that the magistrate court “had the authority to determine each party’s interest in jointly owned separate property.” The district court determined that, since the magistrate court properly handled the tracing of separate and community contributions to the Island Park Properties, “Wright’s claim to a greater ownership interest [was] barred by the doctrine of claim preclusion[.]” To succeed on a theory of claim preclusion, a party must show three elements—“(1) same parties; (2) same claim; and (3) final judgment.” Ticor Title Co., 144 Idaho at 124 , 157 P.3d at

2023Instead, the district court found that the magistrate court “had the authority to determine each party’s interest in jointly owned separate property.” The district court determined that, since the magistrate court properly handled the tracing of separate and community contributions to the Island Park Properties, “Wright’s claim to a greater ownership interest [was] barred by the doctrine of claim preclusion[.]” To succeed on a theory of claim preclusion, a party must show three elements—“(1) same parties; (2) same claim; and (3) final judgment.” Ticor Title Co., 144 Idaho at 124 , 157 P.3d at

12023–2023
Stoddard v. Hagadone Corp. green
idaho · 2009
1 sentence

2022Id.

12022–2022
Hindmarsh v. Mock green
idaho · 2002
2 sentences

2007Hindmarsh, 138 Idaho at 94 , 57 P.3d at 805 ; Farmers Nat’l Bank v. Shirey, 126 Idaho 63, 68 , 878 P.2d 762, 767 (1994).

2007Hindmarsh, 138 Idaho at 94 , 57 P.3d at 805 ; Farmers Nat’l Bank v. Shirey, 126 Idaho 63, 68 , 878 P.2d 762, 767 (1994).

12007–2007
Aldape v. Akins green
idahoctapp · 1983
2 sentences

1985Moreover, as we recently noted in Aldape v. Akins, 105 Idaho 254 , 668 P.2d 130 (Ct.App.1983), the Joyce-Ramseyer version of res judicata is now known as the doctrine of claim preclusion.

1985Moreover, as we recently noted in Aldape v. Akins, 105 Idaho 254 , 668 P.2d 130 (Ct.App.1983), the Joyce-Ramseyer version of res judicata is now known as the doctrine of claim preclusion.

11985–1985

Statutes the citing opinions construe

ID § Idaho Code § 12-121 (8)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 72 (1993–2026) WI 55 (1996–2026) TN 54 (1996–2025) OR 40 (1990–2024) OH 34 (1999–2026) MA 26 (1993–2025) CO 26 (1993–2025) AZ 21 (2006–2024) OK 19 (1994–2023) UT 18 (1994–2024) IA 17 (1983–2021) NM 17 (1994–2023) VT 16 (1989–2026) NV 14 (2007–2023) CT 13 (1994–2016) WA 13 (1995–2026) NY 11 (1978–2023) DC 10 (1989–2019) TX 10 (2001–2017) ID 10 (1985–2025) MD 9 (2003–2015) NE 8 (2017–2026) KS 7 (1988–2026) ME 7 (2001–2024) MT 6 (1999–2021) MS 6 (2001–2012) DE 6 (2012–2022) MO 5 (2006–2022) IN 5 (1986–2026) LA 4 (1995–2026) PA 4 (1998–2019) MI 3 (1998–2016) FL 3 (1993–2007) NJ 3 (1998–2017) NH 3 (2015–2020) AL 3 (1998–2008) IL 2 (1997–1997) VA 2 (2015–2015) AR 2 (1988–1994) KY 2 (2011–2022) AK 2 (2005–2025) NC 2 (2009–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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