res judicata doctrine in Idaho

2000As a general matter, the doctrine of res judicata holds that ‘“in an action between the same parties upon the same claim or demand, the former adjudication concludes parties and privies ... as to every matter offered and received to sustain or defeat the claim____’” Diamond v. Farmers Group, Inc., 119 Idaho 146, 150 , 804 P.2d 319, 323 (1990) (quoting Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549, 553 , 208 P. 241, 242 (1922)).

2000As a general matter, the doctrine of res judicata holds that ‘“in an action between the same parties upon the same claim or demand, the former adjudication concludes parties and privies ... as to every matter offered and received to sustain or defeat the claim____’” Diamond v. Farmers Group, Inc., 119 Idaho 146, 150 , 804 P.2d 319, 323 (1990) (quoting Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549, 553 , 208 P. 241, 242 (1922)).

2000As a general matter, the doctrine of res judicata holds that ‘“in an action between the same parties upon the same claim or demand, the former adjudication concludes parties and privies ... as to every matter offered and received to sustain or defeat the claim____’” Diamond v. Farmers Group, Inc., 119 Idaho 146, 150 , 804 P.2d 319, 323 (1990) (quoting Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549, 553 , 208 P. 241, 242 (1922)).

2000As a general matter, the doctrine of res judicata holds that ‘“in an action between the same parties upon the same claim or demand, the former adjudication concludes parties and privies ... as to every matter offered and received to sustain or defeat the claim____’” Diamond v. Farmers Group, Inc., 119 Idaho 146, 150 , 804 P.2d 319, 323 (1990) (quoting Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549, 553 , 208 P. 241, 242 (1922)).

2026HLV cites Duthie v. Lewiston Gun Club, 104 Idaho 751 , 753–54, 663 P.2d 287 , 289–90 (1983), for the proposition that res judicata can be raised at any time because that doctrine “applies to every matter which might and should have been litigated in the first suit whether or not it was raised in the pleadings.” However, HLV’s reliance on Duthie is misplaced because in Duthie, the issue was raised by a party; thus, it did not address whether it is appropriate for a court to raise a res judicata defense sua sponte.

2026HLV cites Duthie v. Lewiston Gun Club, 104 Idaho 751 , 753–54, 663 P.2d 287 , 289–90 (1983), for the proposition that res judicata can be raised at any time because that doctrine “applies to every matter which might and should have been litigated in the first suit whether or not it was raised in the pleadings.” However, HLV’s reliance on Duthie is misplaced because in Duthie, the issue was raised by a party; thus, it did not address whether it is appropriate for a court to raise a res judicata defense sua sponte.

2023Additionally, in Schultz v. State, the Idaho Court of Appeals applied res judicata against a defendant who argued his trial counsel was ineffective for failing to enforce his plea agreement. 153 Idaho 791, 797 , 291 P.3d 474, 480 (Ct. App. 2012).

2023Additionally, in Schultz v. State, the Idaho Court of Appeals applied res judicata against a defendant who argued his trial counsel was ineffective for failing to enforce his plea agreement. 153 Idaho 791, 797 , 291 P.3d 474, 480 (Ct. App. 2012).

2014Two of the fundamental pur poses served by the doctrine of res judicata are: (a) “[I]t- serves the public interest in protecting the courts against the burdens of repetitious litigation” and (b) “[I]t advances the private interest in repose from the harassment of repetitive claims.” Id. at 123 , 157 P.3d at 617 . (1) Same parties. “[T]he doctrine of res judicata (claim preclusion) bars the presentation of the claim in a subsequent lawsuit between the same parties or their privies.” Devil Creek Ranch, Inc. v. Cedar Mesa Reservoir and Canal Co., 123 Idaho 634, 637 , 851 P.2d 348, 351 (1993).

2014Two of the fundamental pur poses served by the doctrine of res judicata are: (a) “[I]t- serves the public interest in protecting the courts against the burdens of repetitious litigation” and (b) “[I]t advances the private interest in repose from the harassment of repetitive claims.” Id. at 123 , 157 P.3d at 617 . (1) Same parties. “[T]he doctrine of res judicata (claim preclusion) bars the presentation of the claim in a subsequent lawsuit between the same parties or their privies.” Devil Creek Ranch, Inc. v. Cedar Mesa Reservoir and Canal Co., 123 Idaho 634, 637 , 851 P.2d 348, 351 (1993).

2013See State v. Pierce, 107 Idaho 96, 102 , 685 P.2d 837, 843 (Ct. App. 1984) (holding that where a ruling in a criminal case is correct, though based upon an incorrect reason, it still may be sustained upon the proper legal theory).

2013See State v. Pierce, 107 Idaho 96, 102 , 685 P.2d 837, 843 (Ct. App. 1984) (holding that where a ruling in a criminal case is correct, though based upon an incorrect reason, it still may be sustained upon the proper legal theory).

2019See, e.g., State v. Rhoades, 134 Idaho 862, 863 , 11 P.3d 481, 482 (2000) (holding “the doctrine of res judicata can be applied to bar a subsequent Rule 35 motion after a defendant has failed to appeal an earlier motion based on the same grounds”).

2019See, e.g., State v. Rhoades, 134 Idaho 862, 863 , 11 P.3d 481, 482 (2000) (holding “the doctrine of res judicata can be applied to bar a subsequent Rule 35 motion after a defendant has failed to appeal an earlier motion based on the same grounds”).

1993Therefore, under the so called Joyce rule, announced in Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549 , 208 P. 241 (1922), and articulated in Aldape v. Akins, 105 Idaho 254 , 668 P.2d 130 (Ct.App.1983), the doctrine of res judicata (claim preclusion) acted to bar Hall’s claims.

1993Therefore, under the so called Joyce rule, announced in Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549 , 208 P. 241 (1922), and articulated in Aldape v. Akins, 105 Idaho 254 , 668 P.2d 130 (Ct.App.1983), the doctrine of res judicata (claim preclusion) acted to bar Hall’s claims.

1983The above passage from Intermountain Food Equipment was augmented by another paragraph in that case which followed immediately: "In further discussing this doctrine, it was stated in Marshall v. Underwood, 38 Idaho 464 , 221 P. 1105 : "`The doctrine of res judicata, or estoppel by judgment, as it is sometimes termed, is a rule of law founded on the soundest consideration of public policy.

1983The above passage from Intermountain Food Equipment was augmented by another paragraph in that case which followed immediately: "In further discussing this doctrine, it was stated in Marshall v. Underwood, 38 Idaho 464 , 221 P. 1105 : "`The doctrine of res judicata, or estoppel by judgment, as it is sometimes termed, is a rule of law founded on the soundest consideration of public policy.

1987The Restatement (Second) of Judgments (1982) has been cited with approvál by this Court in Houser v. Southern Idaho Pipe & Steel, Inc., 103 Idaho 441, 446 , 649 P.2d 1197, 1202 (1982) and Ramseyer v. Ramseyer, 98 Idaho 554, 556 , 569 P.2d 358, 360 (1977).

1987The Restatement (Second) of Judgments (1982) has been cited with approvál by this Court in Houser v. Southern Idaho Pipe & Steel, Inc., 103 Idaho 441, 446 , 649 P.2d 1197, 1202 (1982) and Ramseyer v. Ramseyer, 98 Idaho 554, 556 , 569 P.2d 358, 360 (1977).

2009As the Supreme Court stated in Nevada v. U.S., 463 U.S. 110, 129-30 , 103 S.Ct. 2906, 2918 , 77 L.Ed.2d 509, 524 (1983) (citations omitted): Simply put, the doctrine of res judicata provides that when a final judgment has been entered on the merits of a case, “[i]t is a finality as to the claim or demand in controversy, concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose.” The final “judgment puts an end to the

2009As the Supreme Court stated in Nevada v. U.S., 463 U.S. 110, 129-30 , 103 S.Ct. 2906, 2918 , 77 L.Ed.2d 509, 524 (1983) (citations omitted): Simply put, the doctrine of res judicata provides that when a final judgment has been entered on the merits of a case, “[i]t is a finality as to the claim or demand in controversy, concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose.” The final “judgment puts an end to the

2019Rodriguez v. Dep’t of Correction, 136 Idaho 90, 92 , 29 P.3d 401, 403 (2001); Anderson v. City of Pocatello, 112 Idaho 176, 183 , 731 P.2d 171, 178 (1986).

2019Rodriguez v. Dep’t of Correction, 136 Idaho 90, 92 , 29 P.3d 401, 403 (2001); Anderson v. City of Pocatello, 112 Idaho 176, 183 , 731 P.2d 171, 178 (1986).

2017In that appeal, we held that Mr. Taylor’s claim, which he alleged in his complaint as being for “professional negligence, malpractice, negligence and/or negligent issuance of an opinion letter” was barred by the doctrine of res judicata. 157 Idaho at 335 , 336 P.3d at 268 .

2017In that appeal, we held that Mr. Taylor’s claim, which he alleged in his complaint as being for “professional negligence, malpractice, negligence and/or negligent issuance of an opinion letter” was barred by the doctrine of res judicata. 157 Idaho at 335 , 336 P.3d at 268 .

2009See Hindmarsh v. Mock, 138 Idaho 92, 94 , 57 P.3d 803, 805 (2002); Wing v. Hulet, 106 Idaho 912, 916 , 684 P.2d 314, 318 (Ct.App.1984) (“the rule against splitting a claim applies even though the remedies or form of relief demanded in one suit are different from those demanded in another.”) The district court’s ruling properly carried out such purpose in its summary judgment order and we therefore affirm.

2009See Hindmarsh v. Mock, 138 Idaho 92, 94 , 57 P.3d 803, 805 (2002); Wing v. Hulet, 106 Idaho 912, 916 , 684 P.2d 314, 318 (Ct.App.1984) (“the rule against splitting a claim applies even though the remedies or form of relief demanded in one suit are different from those demanded in another.”) The district court’s ruling properly carried out such purpose in its summary judgment order and we therefore affirm.

1996The rule of res judicata is that “in an action between the same parties upon the same claim or demand, the former adjudication concludes parties and privies not only as to every matter offered and received to sustain or defeat the claim but also as to every matter which might and should have been litigated in the first suit.” Magic Valley Radiology, P.A. v. Kolouch, 123 Idaho 434, 436-37 , 849 P.2d 107, 109-10 (1993) (quoting Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549, 553 , 208 P. 241, 242-43 (1922)).

1996The rule of res judicata is that “in an action between the same parties upon the same claim or demand, the former adjudication concludes parties and privies not only as to every matter offered and received to sustain or defeat the claim but also as to every matter which might and should have been litigated in the first suit.” Magic Valley Radiology, P.A. v. Kolouch, 123 Idaho 434, 436-37 , 849 P.2d 107, 109-10 (1993) (quoting Joyce v. Murphy Land & Irrigation Co., 35 Idaho 549, 553 , 208 P. 241, 242-43 (1922)).

1987Accordingly, it has now become final, and the doctrine of res judicata applies not only as to all matters decided, but also as to "every matter which might and should have been litigated in the first suit." Duthie v. Lewiston Gun Club, 104 Idaho 751, 753 , 663 P.2d 287, 289 (1983); Intermountain Food Equipment Co. v. Waller, 86 Idaho 94, 98 , 383 P.2d 612, 615 (1963); Joyce v. Murphy Land & Irr.

1987Accordingly, it has now become final, and the doctrine of res judicata applies not only as to all matters decided, but also as to "every matter which might and should have been litigated in the first suit." Duthie v. Lewiston Gun Club, 104 Idaho 751, 753 , 663 P.2d 287, 289 (1983); Intermountain Food Equipment Co. v. Waller, 86 Idaho 94, 98 , 383 P.2d 612, 615 (1963); Joyce v. Murphy Land & Irr.

2017“Where a lower court makes a ruling based on two alternative grounds and only one of those grounds is challenged on appeal, the appellate court must affirm on the uncontested basis.” State v. Grazian, 144 Idaho 510, 517-18 , 164 P.3d 790, 797-98 (2007).

2017“Where a lower court makes a ruling based on two alternative grounds and only one of those grounds is challenged on appeal, the appellate court must affirm on the uncontested basis.” State v. Grazian, 144 Idaho 510, 517-18 , 164 P.3d 790, 797-98 (2007).

1980Cf. Green v. Gough, 96 Idaho 927 , 539 P.2d 280 (1975); Gaige v. City of Boise, 91 Idaho 481 , 425 P.2d 52 (1967); Intermountain Food Equipment Co. v. Waller, 86 Idaho 94 , 383 P.2d 612 (1963); (cited opinions apply a similar rule to cases involving doctrine of res judicata).

1980Cf. Green v. Gough, 96 Idaho 927 , 539 P.2d 280 (1975); Gaige v. City of Boise, 91 Idaho 481 , 425 P.2d 52 (1967); Intermountain Food Equipment Co. v. Waller, 86 Idaho 94 , 383 P.2d 612 (1963); (cited opinions apply a similar rule to cases involving doctrine of res judicata).

2026However, “[a]n unpleaded issue is not tried by express or implied consent when nothing in the record indicates the issue was litigated at trial.” Fickenwirth v. Lanning, 173 Idaho 1 , 6, 538 P.3d 370, 375 (2023) (alteration in original) (emphasis added) (quoting Gestner v. Divine, 171 Idaho 159, 174 , 519 P.3d 439, 454 (2022)). 14 For these reasons, we reverse the district court’s decision to the extent that it based its dismissal of the Stasiewiczes’ claims pursuant to an affirmative defense—the doctrine of res judicata—that it raised sua sponte.

2026However, “[a]n unpleaded issue is not tried by express or implied consent when nothing in the record indicates the issue was litigated at trial.” Fickenwirth v. Lanning, 173 Idaho 1 , 6, 538 P.3d 370, 375 (2023) (alteration in original) (emphasis added) (quoting Gestner v. Divine, 171 Idaho 159, 174 , 519 P.3d 439, 454 (2022)). 14 For these reasons, we reverse the district court’s decision to the extent that it based its dismissal of the Stasiewiczes’ claims pursuant to an affirmative defense—the doctrine of res judicata—that it raised sua sponte.

2026However, “[a]n unpleaded issue is not tried by express or implied consent when nothing in the record indicates the issue was litigated at trial.” Fickenwirth v. Lanning, 173 Idaho 1 , 6, 538 P.3d 370, 375 (2023) (alteration in original) (emphasis added) (quoting Gestner v. Divine, 171 Idaho 159, 174 , 519 P.3d 439, 454 (2022)). 14 For these reasons, we reverse the district court’s decision to the extent that it based its dismissal of the Stasiewiczes’ claims pursuant to an affirmative defense—the doctrine of res judicata—that it raised sua sponte.

2023Otter, 148 Idaho 324, 338 , 223 P.3d 266, 280 (2009) (quoting Nevada v. United States, 463 U.S. 110, 129-30 (1983)).

2023Otter, 148 Idaho 324, 338 , 223 P.3d 266, 280 (2009) (quoting Nevada v. United States, 463 U.S. 110, 129-30 (1983)).

2023State v. Shanahan, 165 Idaho 343, 352-53 , 445 P.3d 152, 161-62 (2019). 5 is consistent with the broad scope of claim preclusion under the analogous doctrine of res judicata.

2023State v. Shanahan, 165 Idaho 343, 352-53 , 445 P.3d 152, 161-62 (2019). 5 is consistent with the broad scope of claim preclusion under the analogous doctrine of res judicata.