Taylor v. Sturgell
United States Supreme Court
553 U.S. 880 (2008)
- Written by DeAnna Swearingen, LLM
Facts
Greg Herrick wanted to restore an old airplane. Under the Freedom of Information Act, Herrick asked the Federal Aviation Administration (FAA) (defendant) to give him its files about that airplane model. The agency possessed hundreds of pages of responsive information. However, the plane’s manufacturer objected, claiming that the documents contained trade secrets, and the agency refused to release them to Herrick. Herrick challenged the decision in federal court and lost. One month later, Herrick's friend Brent Taylor (plaintiff) asked the FAA for the exact same documents. Noticing the similarity, the agency ignored Taylor’s request. Taylor filed his own lawsuit in a different district court. Taylor was represented by the same lawyer who had represented Herrick and relied on the same legal theory. Applying the doctrine of virtual representation, the district court found that Taylor’s interests had been represented in Herrick’s earlier lawsuit de facto and, therefore, that claim preclusion prevented Taylor's lawsuit. The United States Court of Appeals for the District of Columbia Circuit affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Ginsburg, J.)
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