Maryland
How Allen v. McCurry applies in Maryland: state-specific rules, key cases, and bar exam notes for Civil Procedure (Preclusion) / Civil Rights (§ 1983).
Maryland law adheres to the principles of issue preclusion and claim preclusion as outlined in Allen v. McCurry, emphasizing the importance of final judgments in prior litigation involving the same parties or their privies. The state recognizes that Section 1983 actions can be barred by previous state court determinations if they involve the same issues.
In Maryland, the doctrine of res judicata (claim preclusion) prevents parties from relitigating claims that were or could have been raised in a prior action between the same parties involving the same cause of action.
Maryland courts held that a prior finding of no liability in a state tort case barred a subsequent Section 1983 claim based on the same underlying facts.
The court found that the dismissal of a state claim for failure to state a claim precluded subsequent federal claims based on the same allegations.
This case affirmed that issue preclusion applies even when the subsequent action is of a different nature, provided the issues are the same.
Maryland's approach to issue and claim preclusion aligns closely with the federal standards set forth in Allen v. McCurry, which require that preclusive effect is given to valid judgments even when different theories of liability are involved. However, state courts may have slightly more flexible interpretations regarding the finality of judgments compared to federal courts.
Candidates should be aware that preclusion doctrines are frequently tested in the Maryland bar exam, particularly in the context of civil rights claims under § 1983, where prior findings can impact the ability to bring new claims.