Ring v. LeightonAnnotate this Case
The Supreme Judicial Court vacated the summary judgment entered by the superior court in favor of Defendant on Plaintiff’s complaint asserting that Defendant was negligent and had caused Plaintiff economic harm, holding that claim preclusion cannot operate to bar a subsequent suit brought in district or superior court by a person who was not an actual party in a previous small claims action.
A third party driving a vehicle owned by Plaintiff was involved in a collision with a vehicle driven by Defendant. In a small claims matter, Defendant sued the third party, and the district court found the third party was negligent. Plaintiff then brought this action against Defendant. The superior court applied the doctrine of res judicata to the earlier small claims judgment and determined that the earlier judgment conclusively resolved the issue of which driver was at fault. The Supreme Court vacated the judgment, holding that, because of the unique limitations of small claims procedure, claim preclusion did not bar this suit by a person who was, at most, in privity with the defendant in the small claims case.