No Second Bite at the Apple: Claiming Collateral Estoppel based on a Prior Workers' Compensation Judgment

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It is said that in law you only get one bite at the apple. However, in the course of a products liability lawsuit, plaintiffs will often try to get as many bites as they can. When plaintiffs file both a workers’ compensation claim and products liability lawsuit based on the same injury, this can potentially serve to benefit defendants. Indeed, an unfavorable workers’ compensation ruling against a plaintiff could be used as a vehicle to get summary judgment through the doctrine of collateral estoppel.

Collateral estoppel is defined as the “binding effect of a judgment as to matters actually litigated and determined in one action on later controversies between the parties involving a different claim from that on which the original judgment was based.” (Black’s Law Dictionary). Collateral estoppel is a form of res judicata, and the terms frequently overlap.

Normally, collateral estoppel is asserted based on a prior ruling by a court of law, but sometimes courts apply the doctrine based upon the prior judgments of administrative law panels. In 1940, the Supreme Court first permitted the application of res judicata based on the rulings of administrative bodies. (Sunshine Anthracite Coal Co. v. Adkins). Then, in 1966, the Supreme Court expanded the application of collateral estoppel by holding that administrative rulings preclude later suits when the administrative body is acting in a judicial capacity and resolves issues that the parties had an adequate opportunity to litigate. (United States v. Utah Constr. & Mining Co.) Based upon these Supreme Court precedents, courts around the country began to apply both res judicata and collateral estoppel to the burgeoning crops of administrative law rulings.

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