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But I Didn’t Get My Day in Court! Collateral Estoppel Versus Due Process

Collateral estoppel is the legal term for the proposition that a Court will not make a decision on the same issue more than once. This theory serves the purpose of avoiding the expense of multiple lawsuits, conserves judicial resources, and generally inspires confidence in the judicial system by minimizing the possibilities of inconsistent decisions.

Collateral estoppel can sometimes raise constitutional issues with respect to due process, when a person was not a party to the earlier litigation. Due Process is a person’s constitutional right to have their case heard. Maryland law does not permit a person’s due process rights to be violated because of collateral estoppel. Maryland Courts have held that findings adverse to nonparties in an earlier litigation cannot be binding upon them. 

This issue was addressed in the case of Bryan v. State Farm Mutual Automobile Insurance Company, 205 Md. App. 587 (2012). In the Bryan case, Plaintiffs, a driver and three passengers, who were Maryland residents, were involved in a motor vehicle accident in New York. Plaintiffs contend that a phantom vehicle changed lanes, cutting off their vehicle and causing their vehicle to collide with two other vehicles.  The driver of Plaintiffs’ vehicle was sued for personal injuries by the driver of one of the other vehicles with which his vehicle collided. None of the passengers were parties to the New York lawsuit. The New York court found that the driver of Plaintiffs’ vehicle, not a phantom vehicle, was at fault for the accident. Subsequent to the New York trial, Plaintiffs (driver and passengers) filed suit against State Farm, pursuant to an uninsured motorist policy, claiming that a phantom vehicle was at fault for the accident. With respect to the driver’s claim, the Maryland Court held that he was barred from bringing his case against State Farm because he was a party to the New York lawsuit, which determined he, and not a phantom vehicle, was at fault for the accident. With respect to the passenger’s claims, the Maryland Court held that their claim could not be barred by collateral estoppel, as they were not parties to the New York lawsuit and therefore would have their due process rights violated if they were unable to bring the lawsuit.

It should be noted that this only applies when the earlier findings are ADVERSE to nonparties. Had the New York court found that a phantom vehicle was at fault for the accident, the passenger Plaintiffs could have used this finding in pursuing their case against State Farm, without having to re-litigate that issue.

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