State Farm Fire & Casualty Co. v. Century Home Components 1976
Defense of Judgments > Issue Preculusion > Offensive & Nonmutual CivPro – pg710 – 10/22/09
Parties: Π – Property Burnt ∆ - Firestarter Procedural History: - Over 50 claims on negligence brought o In Pacific NW Bell ∆ won then had appealed reversed Later lost bench trial and appeal o In Sylwester ∆ won jury trial w/ no appeal o In Hesse ∆ lost jury and had appeal affirmed - Currently an appeal of 13 out of 48 consolidated cases which had amended & supplemented complaints to conform to Bell and Hesse complaints o Trial court ruled for π Facts: - Fire of unknown cause originated in ∆ skip box next to wearhouse where prefabricated housing was being constructed o Π shed was connected by wooding loading dock 60 ft away Damaged by fire Legal Issue: Can offensive, nonmutual issue preclusion be brought when there are inconsistent prior judgments? Holding: No. A ∆ may retry an issue if previous judgments are inconsistent. Reasoning: - “Multiple-claimant anomaly” first hypothesized by Brainerd Currie having unfair results o If 24 separate verdicts are for the ∆, then a 25th for π, should the 26th be estopped? No, it’s anomaly Therefore, neither should the 2nd verdict Conclusion: Ø apply estoppel when ∆ potentially faces more than two successive actions o Largely academic as inconsistent verdicts are very rare o Fails to recognize that collateral estoppel demands and assumes a certain confidence in the integrity of the end result of our adjudicative process But court “not free to disregard incongruous results when they are looking us in the eye” RSJ§88 – if prior determination was manifestly erroneous then no preclusion If new evidence, then Ø apply preclusion - Court gives little credence to idea that Sylwester and Hesse can be distinguished o Would allow π to slightly change wording unfairly - Therefore, when prior determinations are basically inconsistent…it would be unfair to preclude ∆s from relitigating Disposition: Reverse & Remand Dissent/Concurrence: N/A