Massachusetts
How Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation applies in Massachusetts: state-specific rules, key cases, and bar exam notes for Civil Procedure.
Massachusetts follows a similar approach to issue preclusion as articulated in Blonder-Tongue, whereby a party who has lost a claim is barred from relitigating that claim or related issues in subsequent cases. However, Massachusetts courts also emphasize a more flexible application of mutuality and fairness, allowing certain exceptions under the right circumstances.
Massachusetts applies a broader doctrine of res judicata that extends not only to claims that were actually litigated but also to claims that could have been raised in the prior action, consistent with the principles laid out in Blonder-Tongue.
The court found that since the essential issue had been resolved in a prior action, subsequent claims were barred under res judicata.
The ruling specified that a party is barred from raising issues that were or could have been decided in a previous litigation concerning the same parties.
The court established that the same facts contributing to liability in a previous case precluded the same claims from being relitigated.
While both Massachusetts and federal courts accept the doctrines of claim and issue preclusion, Massachusetts tends to allow for more exceptions to mutuality compared to the strict federal rules. This flexibility includes considerations of fairness and the potential for new evidence that could impact the litigation outcome.
The principles of res judicata and issue preclusion from Blonder-Tongue are often tested in the Massachusetts bar exam, especially concerning their application and exceptions within the context of civil procedure.