Little v. Blue Goose Motor Coach Co.
178 N. E. 496, 346 Ill. 266 (1931)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under the doctrine of estoppel by verdict (issue preclusion), a final judgment on the merits that necessarily determines an issue, such as a party's negligence in causing an accident, is conclusive and bars the re-litigation of that same issue in a subsequent suit between the same parties or their privies, even if the cause of action is different.
Facts:
- Dr. Robert M. Little was driving his automobile when he collided with a passenger bus owned and operated by Blue Goose Motor Coach Company.
- Following the collision, Blue Goose Motor Coach Company sued Dr. Little in a justice of the peace court for property damage to its bus.
- The justice of the peace court entered a judgment in favor of Blue Goose Motor Coach Company and against Dr. Little for $139.35.
- While the property damage suit was pending, Dr. Little filed a separate lawsuit against Blue Goose Motor Coach Company to recover for personal injuries he sustained in the same collision.
- Before his personal injury suit concluded, Dr. Little died, and his widow was substituted as the plaintiff to pursue a wrongful death claim.
Procedural Posture:
- Blue Goose Motor Coach Company sued Dr. Little in a justice of the peace court and obtained a judgment for $139.35 for property damage.
- Dr. Little appealed the judgment to the county court, but the appeal was dismissed for want of prosecution, making the justice court judgment final.
- Dr. Little's widow, as plaintiff, obtained a $5000 judgment against Blue Goose Motor Coach Company in a wrongful death action in the city court of East St. Louis.
- Blue Goose Motor Coach Company, as appellant, appealed to the Appellate Court for the Fourth District.
- The Appellate Court reversed the city court's judgment without remanding and issued a finding of fact that the issue of Dr. Little's negligence had been settled in the prior justice court case.
- The plaintiff, as plaintiff in error, was granted a writ of certiorari by the Supreme Court of Illinois to review the Appellate Court's judgment.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a final judgment in a property damage lawsuit, which necessarily determined that a decedent was negligent in an automobile collision, preclude the decedent's representative from subsequently bringing a wrongful death action against the same opponent based on the same collision?
Opinions:
Majority - Per Curiam
Yes. A final judgment that necessarily determined the decedent's negligence in a prior action precludes his representative's subsequent wrongful death claim. The doctrine of estoppel by verdict applies because the material fact of negligence was determined in a former suit between parties in privity. The right to recover damages under the Illinois Injuries Act is derivative; the plaintiff can only bring an action if the deceased could have maintained one for his injuries had he lived. Since the justice of the peace court's judgment established Dr. Little's negligence, he would have been barred from recovering, and therefore his widow is also barred. This conclusion extends to the count for willful and wanton conduct, as the finding that Dr. Little's negligence caused the collision necessarily determined that the bus driver was not guilty of willful negligence.
Analysis:
This case solidifies the application of issue preclusion, or estoppel by verdict, to matters arising from the same transaction but involving different causes of action (property damage versus wrongful death). It underscores the derivative nature of wrongful death statutes, establishing that the representative's claim is entirely dependent on the decedent's ability to have successfully brought a claim. This precedent warns litigants that the outcome of even a small claims case can have a profound preclusive effect on subsequent, higher-stakes litigation, as the determination of a core issue like fault becomes binding.
