Taylor v. Sturgell (2007)
- Docket
- 07-371
- Decided
- 2007-01-01
Summary
Question: Does the dismissal of a claim based on a Freedom of Information Act request preclude a second individual, based on the concept of "virtual representation," from bringing a similar claim when both claims involve the same project and the parties to each suit are represented by the same attorney? Conclusion: No. Writing for a unanimous Court, Justice Ruth Bader Ginsburg held that such "nonparty preclusion" runs up against the "deep-rooted historic tradition that everyone should have his own day in court." Virtual representation should only be applied rarely and under certain exceptions to the general rule, none of which the Court found applicable in this case. The D.C. Circuit's decision was vacated and the case sent back to the district court for a new trial.