20 Thames Street LLC v. Ocean State Job Lot of Maine 2017 LLC
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The Supreme Judicial Court vacated the decision of the superior court affirming the judgment of the district court entered in the Business and Consumer Docket in favor of Ocean State Job Lot of Maine 2017 LLC and dismissing the action brought by 20 Thames Street LLC and 122 PTIP LLC (collectively, 20 Thames) for forcible entry and detainer (FED), holding that the district court erred.
In granting Ocean State's motion to dismiss, the district court determined that 20 Thames's complaint for FED was barred by the claim preclusion branch of res judicata. The superior court affirmed. On appeal, 20 Thames argued that the trial court erred in dismissing the action on claim preclusion grounds because one claim was not and could not have been litigated in an earlier action. The Supreme Court agreed and reversed, holding (1) claim preclusion did not apply; and (2) where it was impossible to discern definitively what was litigated and decided in the earlier action, issue preclusion should not foreclose an inquiry into the merits.
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