Utah
How Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation applies in Utah: state-specific rules, key cases, and bar exam notes for Civil Procedure (Collateral Estoppel/Issue Preclusion) and Patent Law.
Utah law follows similar principles regarding collateral estoppel and issue preclusion as established in Blonder-Tongue Laboratories. In Utah, a party may be estopped from relitigating issues that have been conclusively determined in a prior action, provided that the parties in both cases are sufficiently aligned.
In Utah, for collateral estoppel to apply, the issue must have been actually litigated and determined in a prior proceeding, the parties must have had a full and fair opportunity to litigate the issue, and the determination must have been essential to the prior judgment.
Collateral estoppel barred relitigation of whether the defendant was guilty of theft after the issue was decided in a previous criminal case.
The court held that issue preclusion applied to an uninsured motorist claim, as the liability was previously determined in a separate coverage action.
The court applied collateral estoppel to preclude the relitigation of a finding regarding the eligibility for unemployment benefits.
Utah's approach to collateral estoppel closely mirrors the federal standard as articulated in Blonder-Tongue, focusing on the necessity of actual litigation and fair opportunity to contest the issue. However, Illinois provides more rigid requirements, whereas Utah allows a broader basis for mutuality between parties.
Understanding collateral estoppel and its application under Utah law is crucial for the state bar exam, particularly in relation to its effect on relitigation of patent issues and broader civil procedures.