Maine Revised Statutes

Me. Rev. Stat. tit. 14, § 7485 (2026)

Effect of judgment

✓ current as of May 2026

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Any fact found or issue adjudicated in a proceeding under this chapter may not be deemed found or adjudicated for the purpose of any other cause of action. The judgment obtained is res judicata as to the amount in controversy. If a plaintiff has reduced the amount of a claim or contract to meet the jurisdictional limits of this chapter, the judgment obtained is res judicata as to the full amount of the debt or contract in controversy. The only recourse from an adverse decision is by appeal. [PL 2009, c. 428, §3 (AMD).]

SECTION HISTORY

PL 1981, c. 667, §2 (NEW). PL 2009, c. 428, §3 (AMD).

Notes of Decisions

Cited in 10 cases, 1986–2019 · leading case: Eric Ring v. Daniel Leighton v. Clinton McGaw, 2019 ME 8 (Me. 2019).

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Eric Ring v. Daniel Leighton v. Clinton McGaw, 2019 ME 8 (Me. 2019). · cites it 8× “[¶14] Either party may appeal a small claims judgment to the Superior Court, 14 M.R.S. § 7485 ; M.R.S.C.P. 11(a), but the plaintiff may appeal "questions of law only," and a plaintiff's appeal "shall be determined by the Superior Court without jury.”

Thibeault v. Brackett, 2007 ME 154 (Me. 2007). “Pursuant to 14 M.R.S. § 7485 (2006), which deals with the effect of a small claims judgment on later actions: [a]ny fact found or issue adjudicated in a proceeding under this chapter, may not be deemed found or adjudicated for the purpose of any other cause of action.”

Caporino v. Lacasse, 511 A.2d 445 (Me. 1986). “More specifically, Caporino contends that under 14 M.R.S.A. § 7485 1 the doctrine of res judicata applies only to the amount recovered in the small claims proceeding and does not foreclose her from seeking subsequent and additional damages in an alternative forum.”

Darling's v. Nissan Motor Corp., 863 F. Supp. 26 (D. Me. 1994). “See 14 M.R.S.A. § 7485 (Supp.1994) ("Any fact found or issue adjudicated in a proceeding [in Small Claims Court], may not be deemed found or adjudicated for the purpose of any other cause of action.”

Eric Ring v. Daniel Leighton v. Clinton McGaw, 2019 ME 8 (Me. 2019). · cites it 6× “We have not 1 Because Ring’s argument that 14 M.R.S. § 7485 (2017) prohibits giving the small claims judgment preclusive effect in the Superior Court “depends on the legal effect of the .”

Campbell v. Poulin (Me. Super. Ct 2004). · cites it 2× “14 M.R.S.A. § 7485.: Defendants here are arguing essentially that the theory of “bar and merger” applies in this case.”

Woodside v. Coppersmith (Me. Super. Ct 2019). “See, 14 M.R.S. § 7485. 3 Defendant filed the first motion for continuance on 11/2 7/18, two days before the original hearing date, although defendant was served with the statement of claim on 10/25/18 and was sent notice of the hearing by the court on 10/3 0/18.”

Darling's Ford v. Ford Motor Co. (Me. Super. Ct 2002). “See 14M.R.S.A. § 7485. As far as the record evidence reveals, neither party had sought an authoritative answer to the question at bar prior to the initiation of this case.”

Barrett v. Brookfield Apts., LLC (Me. Super. Ct 2005). “14 M.R.S.A. § 7485 (2003) reads: Any fact found or issue adjudicated in a proceeding under this chapter, may not be deemed found or adjudicated for the purpose of any other cause of action.”

City of Portland v. Coyne (Me. Super. Ct 2010). “Additionally, if the City is concerned about the precedent this case may set, the court notes that Small Claims judgments do not have any value as precedent.”

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