Res Judicata
Res Judicata, Doctrine of
Except as indicated, all indented material is copied directly from the court’s opinion.
Opinions of the Tennessee Supreme Court
Regions Bank v. Prager, 625 S.W.3d 842, 848 (Tenn. 2021).
Tennessee law provides—and the parties agree in this Court—that a trial court’s decision that a claim is barred by the doctrine of res judicata involves a question of law, which appellate courts review de novo without a presumption of correctness.
Decisions of the Tennessee Court of Appeals
Goetz v. Autin, No. W2022-00393-COA-R3-CV, p. 17 (Tenn. Ct. App. Mar. 17, 2023).
A trial court’s determination that the doctrine of res judicata bars a claim also involves a question of law, Regions Bank v. Prager, 625 S.W.3d 842, 848 (Tenn. 2021) (citations omitted), as does a trial court’s decision regarding the issue of standing. Metro. Gov’t of Nashville & Davidson Cnty. v. Tennessee Dep’t of Educ., 645 S.W.3d 141, 147 (Tenn. 2022) (citation omitted). Our review of a trial court’s determinations on questions of law is de novo with no presumption of correctness. Cooper v. Mandy, 639 S.W.3d 29, 33 (Tenn. 2022).
Gentry v. Speaker of the House, No. M2022-00654-COA-R3-CV, p. 2 (Tenn. Ct. App. Jan. 27, 2023).
The application of res judicata is a matter of law that we review de novo with no presumption of correctness.Ralph v. Scruggs Farm Supply LLC, 470 S.W.3d 48, 52 (Tenn. Ct. App. 2014).
Nesmith v. Clemmons, No. M2021-01030-COA-R3-CV (Tenn. Ct. App. Jan. 17, 2023).
“A trial court’s decision that a claim is barred by the doctrine of res judicata or claim preclusion involves a question of law which will be reviewed de novo on appeal without a presumption of correctness.” Jackson v. Smith, 387 S.W.3d 486, 491 (Tenn. 2012).
Bank of New York Mellon v. Chamberlain, No. M2021-00684-COA-R3-CV, p. 13 (Tenn. Ct. App. Aug. 1, 2022).
“A trial court’s determination of the applicability of res judicata . . . is a question of law, which we review de novo with no presumption of correctness.” In re Taylor B.W., 397 S.W.3d 105, 111 (Tenn. 2013).
Albers v. Powers, No. M2021-00577-COA-R3-CV (July 12, 2022).
This appeal requires us to construe Tenn. R. Civ. P. 13.01 and consider its interplay with the doctrine of res judicata. The interpretation of a rule of civil procedure and the determination of whether a claim is barred by the doctrine of res judicata are questions of law, which we review de novo with no presumption of correctness. Fair v. Cochran, 418 S.W.3d 542, 544 (Tenn. 2013); In re Est. of Goza, 397 S.W.3d 564, 566 (Tenn. Ct. App. 2012). When interpreting rules of civil procedure, we are guided by the rules of statutory construction, keeping in mind that “[o]ur duty is to enforce the rule as written.” Fair, 418 S.W.3d at 544 (citing Waldschmidt v. Reassure Am. Life Ins. Co., 271 S.W.3d 173, 176 (Tenn. 2008)).
