transactional test (Arizona) · Go Syfert
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transactional test in Arizona

7 Arizona opinions name it 2 courts 1971–2023 1 in the last five years

The cases below were cited by Arizona 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
Smith v. BL Cos.green
connappct · 2018 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023See Smith v. BL Companies, Inc., 198 A.3d 150, 158 (Conn. App. Ct. 2018) (noting that because “claims are the same for res judicata purposes, this court has adopted the transactional test,” which means that “res judicata extinguishes all rights of the plaintiff to remedies against the defendant with respect to all or any part of the transaction, or series of connected transactions, out of which the action arose”). ¶65 Both in the superior court and on appeal, the Trustee has not disputed that these elements were shown.

11
In Re the General Adjudication of All Rights to Use Water in the Gila River System & Sourcegreen
ariz · 2006 · cited in 1 Arizona opinions naming this issue, 2017–2017
2 sentences

2017Under the transactional analysis, the focus is on whether multiple claims arise out of a “common nucleus of operative facts.” Gila River, 212 Ariz. at 71 ¶¶ 20–21 (internal quotation marks omitted). ¶24 In this case, applying the transactional analysis leads us to conclude that the two proceedings at issue involve the same claim.

2017See id. ¶¶ 19–21.

11
United Mine Workers of America v. Gibbsred
scotus · 1966 · cited in 1 Arizona opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., United Mine Workers, 383 U.S. at 725 , 86 S.Ct. 1130 (holding that for purposes of pendent jurisdiction the “state and federal claims must derive from a common nucleus of operative fact”); Reeves v. Beardall, 316 U.S. 283, 286 , 62 S.Ct. 1085 , 86 L.Ed. 1478 (1942) (holding that because the plaintiffs “two claims arose out of wholly separate and distinct transactions,” the district court’s decision on one claim was a final judgment for purposes of Rule 54(b)). ¶ 22 We assume, without deciding, that the federal courts would utilize the Second Restatement’s transactional test for dete

2006See, e.g., United Mine Workers, 383 U.S. at 725 , 86 S.Ct. 1130 (holding that for purposes of pendent jurisdiction the “state and federal claims must derive from a common nucleus of operative fact”); Reeves v. Beardall, 316 U.S. 283, 286 , 62 S.Ct. 1085 , 86 L.Ed. 1478 (1942) (holding that because the plaintiffs “two claims arose out of wholly separate and distinct transactions,” the district court’s decision on one claim was a final judgment for purposes of Rule 54(b)). ¶ 22 We assume, without deciding, that the federal courts would utilize the Second Restatement’s transactional test for dete

11
Ross v. International Brotherhood Of Electrical Workersgreen
ca9 · 1980 · cited in 1 Arizona opinions naming this issue, 1997–1997
1 sentence

1997Id.; see Moore et al., supra ¶ 0.410[1] at III-193-94 (stating that any difference between Restatement (Second) § 24 and Rule 13(a), Fed.R.Civ.P. definitions of “transaction or occurrence” is insignificant); cf. Ariz.R.Civ.P. 13(a) (compulsory counterclaim rule).

11
State v. Vallejosgreen
ariz · 1960 · cited in 1 Arizona opinions naming this issue, 1971–1971
2 sentences

1971In each case the facts must be examined to determine whether the transactional test has been met.” 89 Ariz. at 82, 83 , 358 P.2d at 182 .

1971In each case the facts must be examined to determine whether the transactional test has been met.” 89 Ariz. at 82, 83 , 358 P.2d at 182 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Rousselle v. Jewett green
ariz · 1966
1 sentence

2019We then made clear that Arizona courts apply the “same evidence” test, precluding a second action when “no additional evidence is needed to prevail in the second action than that needed in the first.” Id. at 240 (citing Rousselle v. Jewett, 101 Ariz. 510 (1966)).

12019–2019
Phoenix Newspapers, Inc. v. Department of Corrections green
arizctapp · 1997
2 sentences

2019Citing this court’s decision in Phoenix Newspapers, Inc. v. Department of Corrections, 188 Ariz. 237 (App. 1997), Father argues the proper legal standard for deciding whether an “identity of claims” exists between the two proceedings is the “transactional approach.” In that case, however, we merely recognized that most federal circuit courts follow the transactional test, which precludes a second action if it “could and should have been asserted in the first action” because it “arises out of the same events.” 188 Ariz. at 241 .

2019Citing this court’s decision in Phoenix Newspapers, Inc. v. Department of Corrections, 188 Ariz. 237 (App. 1997), Father argues the proper legal standard for deciding whether an “identity of claims” exists between the two proceedings is the “transactional approach.” In that case, however, we merely recognized that most federal circuit courts follow the transactional test, which precludes a second action if it “could and should have been asserted in the first action” because it “arises out of the same events.” 188 Ariz. at 241 .

12019–2019
General Care Corp. v. Olsen green
tenn · 1986
1 sentence

2013Care Corp., 705 S.W.2d 642 (superseded by Tenn.Code Ann. § 67-4-2004). ¶ 12 The parties and Amicus Multistate Tax Commission (“MTC”) agree that the first clause of A.R.S. § 43-1131(1) imposes a transactional test.

12013–2013
Lenox, Inc. v. Tolson green
nc · 2001
2 sentences

2013“The key inquiry under the functional test should be the relationship of the assets acquired, managed, or disposed of to the taxpayer’s existing business at the time the income was realized, not to some future business operations that may be funded by the proceeds from the property.” Hellerstein ¶ 9.05[2][b], at S9-30 (emphasis in original) (criticizing Lenox, Inc. v. Tolson, 353 N.C. 659 , 548 S.E.2d 513 (2001)). ¶ 29 Finally, Taxpayer’s interpretation would result in a lack of symmetry.

2013“The key inquiry under the functional test should be the relationship of the assets acquired, managed, or disposed of to the taxpayer’s existing business at the time the income was realized, not to some future business operations that may be funded by the proceeds from the property.” Hellerstein ¶ 9.05[2][b], at S9-30 (emphasis in original) (criticizing Lenox, Inc. v. Tolson, 353 N.C. 659 , 548 S.E.2d 513 (2001)). ¶ 29 Finally, Taxpayer’s interpretation would result in a lack of symmetry.

12013–2013
Reeves v. Beardall green
scotus · 1942
2 sentences

2006See, e.g., United Mine Workers, 383 U.S. at 725 , 86 S.Ct. 1130 (holding that for purposes of pendent jurisdiction the “state and federal claims must derive from a common nucleus of operative fact”); Reeves v. Beardall, 316 U.S. 283, 286 , 62 S.Ct. 1085 , 86 L.Ed. 1478 (1942) (holding that because the plaintiffs “two claims arose out of wholly separate and distinct transactions,” the district court’s decision on one claim was a final judgment for purposes of Rule 54(b)). ¶ 22 We assume, without deciding, that the federal courts would utilize the Second Restatement’s transactional test for dete

2006See, e.g., United Mine Workers, 383 U.S. at 725 , 86 S.Ct. 1130 (holding that for purposes of pendent jurisdiction the “state and federal claims must derive from a common nucleus of operative fact”); Reeves v. Beardall, 316 U.S. 283, 286 , 62 S.Ct. 1085 , 86 L.Ed. 1478 (1942) (holding that because the plaintiffs “two claims arose out of wholly separate and distinct transactions,” the district court’s decision on one claim was a final judgment for purposes of Rule 54(b)). ¶ 22 We assume, without deciding, that the federal courts would utilize the Second Restatement’s transactional test for dete

12006–2006
Car Carriers, Inc. v. Ford Motor Company green
ca7 · 1986
1 sentence

1997See Restatement, supra at cmt. e; Robinson v. National Cash Register Co., 808 F.2d 1119 (5th Cir.1987); Car Carriers, Inc. v. Ford Motor Co., 789 F.2d 589 (7th Cir.1986).

11997–1997
Chester R. Robinson and Wife, Frances Earline Robinson, and Roy K. Ewart and David B. Black v. The National Cash Register Company green
ca5 · 1987
1 sentence

1997See Restatement, supra at cmt. e; Robinson v. National Cash Register Co., 808 F.2d 1119 (5th Cir.1987); Car Carriers, Inc. v. Ford Motor Co., 789 F.2d 589 (7th Cir.1986).

11997–1997
State v. Harvey green
ariz · 1965
2 sentences

1971(Emphasis supplied.) In State v. Harvey, 98 Ariz. 70 , 402 P.2d 17 (1965), we indicated that “the conduct zvhich occurred on the day in question * * * was the basis of both convictions and therefore the latter conviction * * * must be reversed.” 98 Ariz. at 73 , 402 P.2d at 20 .

1971(Emphasis supplied.) In State v. Harvey, 98 Ariz. 70 , 402 P.2d 17 (1965), we indicated that “the conduct zvhich occurred on the day in question * * * was the basis of both convictions and therefore the latter conviction * * * must be reversed.” 98 Ariz. at 73 , 402 P.2d at 20 .

11971–1971

Where else courts name it

IL 165 (1980–2026) NY 87 (1970–2025) CT 54 (1989–2022) MI 42 (1972–2026) CA 32 (1973–2025) ME 28 (1982–2024) TX 26 (1982–2025) OR 18 (1984–2021) TN 17 (1986–2024) PA 16 (1979–2016) RI 15 (1997–2026) NM 15 (1997–2016) FL 13 (1977–2024) VA 13 (1992–2013) WI 11 (1979–2025) MD 11 (1972–2016) MA 11 (1976–2011) WA 10 (1996–2023) LA 10 (1989–2015) NJ 8 (1974–2025) AZ 7 (1971–2023) AL 7 (1992–2023) IN 7 (1981–2017) KS 6 (1994–2024) UT 6 (2012–2024) NC 6 (1990–2001) OH 5 (2003–2026) WY 4 (1990–2020) WV 3 (1981–2016) SC 3 (1994–2002) IA 3 (1994–2016) AR 3 (1977–2026) ID 3 (1974–2020) OK 3 (1985–2009) MS 2 (1988–2010) MO 2 (2012–2017) VI 2 (2004–2017) DE 2 (2021–2025) MN 2 (1985–1998) CO 2 (1985–1995) HI 2 (1980–1993) GA 2 (2013–2013) AK 2 (1992–2014) MT 2 (1981–2009)

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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