Taylor v. Sturgell

553 U.S. 880, 128 S. Ct. 2161, 171 L. Ed. 2d 155 · Supreme Court of the United States · 2008

Civil Procedure Assigned in 12 casebooks

Case brief summary

Rule

A court judgment usually only binds the people who were actually parties to that lawsuit, not outsiders, though there are a few narrow exceptions where someone who was not a party can still be bound by the result.

Facts

Herrick sued the FAA for old airplane documents and lost. His friend Taylor, who shared a lawyer and documents with him, then filed his own request and lawsuit for the same documents.

Procedural history

Lower courts blocked Taylor's lawsuit, saying Herrick had acted as his 'virtual representative' in the earlier case. The Supreme Court took the case because courts disagreed on this idea.

Issue

Can someone who was never part of a lawsuit be stopped from suing later just because they were closely connected to someone who already lost a similar case?

Holding

The Court rejected the virtual representation theory. Taylor's suit could only be blocked under traditional rules, which didn't apply here. The case was sent back to check if he secretly acted as Herrick's agent.

Reasoning

The Court explained that letting someone be bound by a case they were not part of goes against the basic right to have your own day in court, so only limited established exceptions apply, like agreeing to be bound, having a legal relationship with a party, being adequately and formally represented with proper safeguards, controlling the earlier suit, suing as someone's agent, or being covered by a special law. The broad, vague virtual representation test did not fit any of these, lacked the protections required for adequate representation, and would let courts create informal class actions without following the real rules for class actions.

Opinions

Majority (Ginsburg): Rejected the virtual representation doctrine, holding nonparties can only be bound under established narrow exceptions, and remanded to check if Taylor acted as Herrick's agent.

Test yourself

Question 1 of 5

What relationship existed between Brent Taylor and Greg Herrick?

4 more questions in the full brief →
Cold call

The professor turns to you.

What documents was Greg Herrick trying to obtain from the FAA, and why?
Try a cold call

In the full brief

The trap

On the exam

Other issues in this opinion

Unlock the full brief free