res judicata doctrine in Pennsylvania

2026Further, [u]nder both federal and Pennsylvania law, a central hallmark of the preclusion doctrine is that a prior judgment may bar relitigation only of a claim that has been decided “on the merits.” Parklane Hosiery Co. v. Shore, 439 U.S. 322 , 326 n.5 [] (1979) (“[u]nder the doctrine of res judicata, a judgment on the merits in a prior suit bars a second suit []”); Mariner Chestnut Partners, L.P. v. Lenfest, 152 A.3d 265, 286 (Pa. Super. 2016) (“[u]nder the doctrine of res judicata, or claim preclusion, a final judgment on the merits by a court of competent jurisdiction will bar any future ac

2024Under both federal and Pennsylvania law, a central hallmark of the preclusion doctrine is that a prior judgment may bar relitigation only of a claim that has been decided “on the merits.” Parklane Hosiery Co. v. Shore, 439 U.S. 322 , 326 n.5 . . . (1979) (“[u]nder the doctrine of res judicata, a judgment on the merits in a prior suit bars a second suit . . .”); Mariner Chestnut Partners, L.P. v. Lenfest, . . . 152 A.3d 265, 286 (Pa. Super. 2016) (“[u]nder the doctrine of res judicata, or claim preclusion, a final judgment on the merits by a court of competent jurisdiction will bar any future a

2025The doctrine of res judicata, or claim preclusion, is “based on public policy and seeks to prevent an individual from being vexed twice for the same cause.” Stevenson v. Silverman, 208 A.2d 786, 788 (Pa. 1965).

2017The doctrine of res judicata holds that “[a] final judgment upon the merits by a court of competent jurisdiction bars any future suit. . . .” Mintz v. Carlton House Partners, Ltd., 595 A.2d 1240, 1245 (Pa. 1991) (quoting Stevenson v. Silverman, 208 A.2d 786, 788 (Pa. 1965)).

2025Pursuant to the doctrine of res judicata, “a judgment on the merits in a prior suit bars a second suit on the same cause of action[.]” Id. (quoting Wilmington Trust, Nat'l Ass'n v. Unknown Heirs, 219 A.3d 1173, 1179 (Pa.Super. 2019) (emphasis removed).

2024Essentially, “[u]nder the doctrine of res judicata, a judgment on the merits in a prior suit bars a second suit on the same cause of action[.]” Wilmington Tr., Nat'l Ass'n v. Unknown Heirs, 219 A.3d 1173, 1179 (Pa. Super. 2019) (emphasis added).

2020The doctrine of res judicata “reflects the refusal of the law to tolerate a multiplicity of litigation.” Day v. Volkswagenwerk Aktiengesellschaft, 464 A.2d 1313, 1316 (Pa. Super. 1983).

2019The doctrine of res judicata “reflects the refusal of the law to tolerate a multiplicity of litigation.” Day v. Volkswagenwerk Aktiengesellschaft, 464 A.2d 1313, 1316 (Pa. Super. 1983).

1995In Dempsey v. Cessna Aircraft Co., 439 Pa.Super. 172 , 653 A.2d 679 (1995) (en banc), the doctrine of res judicata was discussed by the Superior Court as follows: *555 The doctrine of res judicata holds that “[a] final valid judgment upon the merits by a court of competent jurisdiction bars any future suit between the same parties or their privies on the same cause of action.” Mintz v. Carlton House Partners, Ltd., 407 Pa.Super. 464, 474 , 595 A.2d 1240, 1245 (1991), quoting Stevenson v. Silverman, 417 Pa. 187, 190 , 208 A.2d 786, 788 (1965), cert. denied, 382 U.S. 833 , 86 S.Ct. 76 , 15 L.Ed.

1995In Dempsey v. Cessna Aircraft Co., 439 Pa.Super. 172 , 653 A.2d 679 (1995) (en banc), the doctrine of res judicata was discussed by the Superior Court as follows: *555 The doctrine of res judicata holds that “[a] final valid judgment upon the merits by a court of competent jurisdiction bars any future suit between the same parties or their privies on the same cause of action.” Mintz v. Carlton House Partners, Ltd., 407 Pa.Super. 464, 474 , 595 A.2d 1240, 1245 (1991), quoting Stevenson v. Silverman, 417 Pa. 187, 190 , 208 A.2d 786, 788 (1965), cert. denied, 382 U.S. 833 , 86 S.Ct. 76 , 15 L.Ed.

2019Co., 650 A.2d 1094, 1096 (Pa. Super. 1994)] (stating that it follows that the doctrine of collateral estoppel may not be raised by preliminary objections); see also Chada v. Chada, . . . 756 A.2d 39, 42-43 (Pa. Super. 2000) (stating that the doctrine of res judicata “subsumes” the modern doctrine of collateral estoppel).

2019“When the cause of action in the first and second actions are distinct, or, even though related, are not so closely related that matters essential to recovery in the second action have been determined in the first action, the doctrine of res judicata does not apply.” Chada v. Chada, 756 A.2d 39, 43-44 (Pa. Super. 2000) (citation omitted).

2019However, the judgment upon which a res judicata claim is based must be a final, valid judgment on the merits of the claim “by a court of competent jurisdiction.” Balent v. City of Wilkes-Barre, 669 A.2d 309, 313 (Pa. 1995) (emphasis added).

2018Under the doctrine of res judicata, Husband may not now raise this issue when it was litigated prior to the trial court’s June 9, 2014, order, and not included in Husband’s prior appeal. - 10 - J-S70042-17 “Res judicata, or claim preclusion, is a doctrine by which a former adjudication bars a later action on all or part of the claim which was the subject of the first action.” Balent v. City of Wilkes-Barre, 669 A.2d 309, 313 (Pa. 1995).

2026An issue of res judicata can be disposed of on preliminary objections where the “facts in th[e] case are not in dispute,” such that the “appellant was not deprived of an opportunity to prove or disprove a fact.” Kelly v. Kelly, 887 A.2d 788, 791 (Pa.Super. 2005). -7- J-S12010-26 Here, the trial court concluded that Solange’s claims were barred by the doctrine of res judicata, noting all elements were satisfied: Where a final judgment on the merits has been rendered by a court of competent jurisdiction, res judicata, or the inability to bring the same action twice, will bar any other suit on th

2016Kelly v. Kelly, 887 A.2d 788, 791 (Pa. Super. 2005) (citations omitted) (noting “doctrine of res judicata ‘subsumes’ the modern doctrine of collateral estoppel”). -8- J-A02029-16 However, as the Kelly Court recognized, there are “very limited circumstances” in which “the trial court’s action of considering the defense of res judicata (or collateral estoppel) raised in the context of a preliminary objection” is not improper.

2026See E.K. v. J.R.A., 237 A.3d 509, 521 (Pa. Super. 2020) (doctrine of res judicata applies to prevent litigants from bearing burden of re-litigating same issues with same parties, and to promote judicial economy).

2025“The dominant inquiry under those elements . . . is whether the controlling issues have been decided in a -9- J-S40016-24 prior action, in which the parties had a full opportunity to assert their rights.” Id. (quoting E.K., 237 A.3d at 521 ).

2021Employer responds that res judicata prevents relitigation of whether Claimant agreed to retire in the settlement agreement, which, Employer argues, constitutes substantial evidence to support the WCJ’s conclusion that Claimant voluntarily retired. “[T]echnical res judicata and collateral estoppel are both encompassed within the parent doctrine of res judicata, which ‘prevents the relitigation of claims and issues in subsequent proceedings.’” Weney, 960 A.2d at 954 (quoting Henion v. Workers’ Comp.

2018Relying on Weney v. Workers’ Compensation Appeal Board (Mac Sprinkler Systems, Inc.), 960 A.2d 949 (Pa. Cmwlth. 2008),2 it reasoned that because Claimant was aware of 2 In Weney, we set forth the criteria necessary to establish res judicata and collateral estoppel: “Initially, we note that technical res judicata and collateral estoppel are both encompassed within the parent doctrine of res judicata, which ‘prevents the relitigation of claims and issues in subsequent proceedings.’ Henion [v. Workers’ Compensation Appeal Board (Firpo & Sons, Inc.)], 776 A.2d [362,] 365 [(Pa. Cmwlth. 2001)].

1991The purpose of the doctrine of res judicata is “to minimize the judicial energy devoted to individual cases, establish certainty and respect for court judgments, and protect the party relying on the prior adjudication from vexatious litigation.” Lebeau v. Lebeau, 258 Pa.Super. 519, 524 , 393 A.2d 480, 492 (1978).

1991The purpose of the doctrine of res judicata is “to minimize the judicial energy devoted to individual cases, establish certainty and respect for court judgments, and protect the party relying on the prior adjudication from vexatious litigation.” Lebeau v. Lebeau, 258 Pa.Super. 519, 524 , 393 A.2d 480, 492 (1978).

2023Co., 902 A.2d 366, 376 (Pa. 2006) (internal citation omitted); see also Henion, 776 A.2d at 365-66 (noting that the doctrine of res judicata “applies to claims that were actually litigated as well as those matters that should have been litigated”).

2023Co., 902 A.2d 366, 376 (Pa. 2006) (internal citation omitted); see also Henion, 776 A.2d at 365-66 (noting that the doctrine of res judicata “applies to claims that were actually litigated as well as those matters that should have been litigated”).

2019The doctrine of res judicata holds that “[a] final judgment upon the merits by a court of competent jurisdiction bars any future suit. . . .” Mintz v. Carlton House Partners, Ltd., 595 A.2d 1240, 1245 (Pa. Super. 1991) (citation omitted).

2017The doctrine of res judicata holds that “[a] final judgment upon the merits by a court of competent jurisdiction bars any future suit. . . .” Mintz v. Carlton House Partners, Ltd., 595 A.2d 1240, 1245 (Pa. 1991) (quoting Stevenson v. Silverman, 208 A.2d 786, 788 (Pa. 1965)).

2025Appellee maintained that Appellants were procedurally barred from bringing their ejectment claims because Appellee had previously prevailed ____________________________________________ 5 “Pursuant to the doctrine of res judicata, a final judgment on the merits by a court of competent jurisdiction will bar any future suit between the parties or their privies in connection with the same cause of action.” Yamulla Trucking & Excavating Co. v. Justofin, 771 A.2d 782, 784 (Pa. Super. 2001).

2017“Pursuant to the doctrine of res judicata, a final judgment on the merits by a court of competent jurisdiction will bar any future suit between the parties or their privies in connection with the same cause of action.” Yamulla Trucking & Excavating Co. v. Justofin, 771 A.2d 782, 784 (Pa. Super. 2001) (emphasis added).

2015See J.S., supra. Although the lower court mistakenly invoked the doctrine of res judicata, its reasoning was sound.

2015See J.S., supra. Although the lower court mistakenly invoked the doctrine of res judicata, its reasoning was sound.

2021This has long been the case.” In our opinion, the doctrine of res judicata … covers all matters which could have been raised or presented in the former action as well as those actually litigated.” Miller v. Dierken, … 41 A.2d 438, 439 ([Pa. Super.] 1945) (citations omitted; emphasis added).

2020“In our opinion, the doctrine of res judicata, which is applicable here, covers all matters which -8- J-A19039-20 could have been raised or presented in the former action as well as those actually litigated.” Miller v. Dierken, 41 A.2d 438, 439 (Pa. Super. 1945) (citations omitted; emphasis added).

2018See Buyfigure.com, Inc. v. Autotrader.com, Inc., 76 A.3d 554, 561 (Pa. Super. 2013) (“The doctrine of res judicata/collateral estoppel applies not only to matters decided, but also to matters that could have, or should have, been raised and decided in an earlier action.”).

2016Perelman v. Perelman, 125 A.3d 1259, 1263, 1265 (Pa. Super. 2015) (citations omitted). “[T]he doctrine of res judicata/collateral estoppel applies not only to matters decided, but also to matters that could have, or should have, been raised and decided in an earlier action.” BuyFigure.com, Inc. v. Autotrader.com, Inc., 76 A.3d 554, 561 (Pa. Super. 2013) (citation and emphasis omitted).

2017See Balent v. City of Wilkes-Barre, 542 Pa. 555 , 669 A.2d 309, 313 (1995) (holding that "[a]ny final, valid judgment on the merits by a court of competent jurisdiction precludes any future suit between the parties or their privies on the same cause of action.”) (emphasis in original) (citing Allen v. McCur-ry, 449 U.S. 90, 94 , 101 S.Ct. 411 , 66 L.Ed.2d 308 (1980)).

2017See Balent v. City of Wilkes-Barre, 542 Pa. 555 , 669 A.2d 309, 313 (1995) (holding that "[a]ny final, valid judgment on the merits by a court of competent jurisdiction precludes any future suit between the parties or their privies on the same cause of action.”) (emphasis in original) (citing Allen v. McCur-ry, 449 U.S. 90, 94 , 101 S.Ct. 411 , 66 L.Ed.2d 308 (1980)).

1988Nedzwecky v. Nedzwecky, 203 Pa.Super. 179, 182 , 199 A.2d 490, 491 (1964), that paternity is a relevant fact necessarily determined and established by the entry of a support order, and therefore, under the doctrine of res judicata, the aggrieved party to a support order may not later challenge that fact in a subsequent proceeding. *622 In this case, the issue of paternity was decided in 1984 when Mr. Ascero chose to enter into the support order and did not appeal that order.

1988Nedzwecky v. Nedzwecky, 203 Pa.Super. 179, 182 , 199 A.2d 490, 491 (1964), that paternity is a relevant fact necessarily determined and established by the entry of a support order, and therefore, under the doctrine of res judicata, the aggrieved party to a support order may not later challenge that fact in a subsequent proceeding. *622 In this case, the issue of paternity was decided in 1984 when Mr. Ascero chose to enter into the support order and did not appeal that order.

2023Co., 902 A.2d 366, 376 (Pa. 2006) (internal citation omitted); see also Henion, 776 A.2d at 365-66 (noting that the doctrine of res judicata “applies to claims that were actually litigated as well as those matters that should have been litigated”).

2023Co., 902 A.2d 366, 376 (Pa. 2006) (internal citation omitted); see also Henion, 776 A.2d at 365-66 (noting that the doctrine of res judicata “applies to claims that were actually litigated as well as those matters that should have been litigated”).

2019Corp., 289 Pa. 260, 263 , 137 A. 252, 253 (1927); ‘The [doctrine of res judicata ] should not be defeated by minor differences of form, parties, or allegations, when these are contrived only to obscure the real purpose,—a second trial on the same cause between the same parties.

2019Corp., 289 Pa. 260, 263 , 137 A. 252, 253 (1927); ‘The [doctrine of res judicata ] should not be defeated by minor differences of form, parties, or allegations, when these are contrived only to obscure the real purpose,—a second trial on the same cause between the same parties.