Taylor v. Sturgell Case Brief

Why is the case important?

Taylor’s friend filed a lawsuit seeking information and was denied. Then Taylor filed a similar action and the court bared suit based on the previous case.

Facts of the case

“Greg Herrick, the owner of one of two F-45s, a rare 1930s vintage airplane, in existence filed a Freedom of Information Act (FOIA) request seeking the plans and specifications for the craft from the Federal Aviation Administration. After the FAA refused to turn over the plans as “”protected trade secrets,”” Herrick filed suit against the FAA to recover the plans. The district court found for the FAA, and the U.S. Court of Appeals for the Tenth Circuit affirmed. Subsequently, roughly a month later, Brent Taylor, represented by Herrick’s attorney, filed another FOIA request seeking the plans. When the request was again denied, Taylor also filed suit in federal court in the District of Columbia.The district court determined that Taylor had been “”virtually represented”” by Herrick in the first suit and therefore could not pursue the second suit in federal court. This judgment was affirmed by the U.S. Court of Appeals for the D.C. Circuit. In seeking Supreme Court review, Taylor argued the D.C. Circuit’s finding that Taylor and Herrick enjoyed a close enough relationship for virtual representation to apply conflicted with several other circuits requiring a much closer nexus to block the second claim. Opposing certiorari, Fairchild Corp. (the airplane manufacturer) arguing on behalf of the FAA, claimed that Taylor had overstated the circuit splits. It also pointed out that, because Taylor and Herrick were collaborating on the plane restoration and were represented by the same attorney, the logical conclusion was that they were attempting to relitigate the same issue.”

Question

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  • Whether a person is bound to a judgment by virtual representation as an appropriate nonparty preclusion.”

    Answer

    No. Parties are only held to a judgment when they are either a designated party to the litigation and were served process to that case. However there are a few exceptions to this rule, virtual representation is one that some courts have chosen to use. This court does not accept such an exception and thus extinguishes this doctrine. The defendants argue that when parties and cases are close enough, the court should find virtual representation. This court disagrees and cites the fundamental rule that a litigant is not bound by a judgment to which he was not a party. The court reviews all valid forms of nonparty preclusion and states that this is different from all acceptable versions. The court also states under adequate representation grounds that the interest must be the same, and the previous litigant must know he or she was acting in a representative capacity for future parties in future lawsuit, which is not the case here. The other issue is allowing this doctrine would allow judges to make de facto class actions at will to bind others. Also this type of exception will create more headaches for courts than help.

    Conclusion

    The United States Supreme Court vacated the judgment and remanded the matter to give the lower courts an opportunity to determine whether petitioner, in pursuing the instant FOIA suit, was acting as his friend’s agent. The Court refused to adopt an amorphous balancing test that was at odds with the Court’s constrained approach to nonparty preclusion. In considering whether the result reached by the lower courts could be justified based on one of the six established grounds, the Court found that a remand was necessary to address the only applicable ground.

    • Case Brief: 2008
    • Petitioner: Brent Taylor
    • Respondent: Robert A. Sturgell, Acting Administrator, Federal Aviation Administration, et al.
    • Decided by: Roberts Court

    Citation: 553 US 880 (2008)
    Granted Jan 11, 2008
    Argued: Apr 16, 2008
    Decided: Jun 12, 2008