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Windel v. Matanuska-Susitna Borough

CIVIL PROCEDURE

Clara Nieman

In Windel v. Matanuska-Susitna Borough, 496 P.3d 392 (Alaska 2021), the supreme court held that (1) an unchallenged res judicata judgment in a prior case bound the parties in the current proceeding and (2) a plaintiff’s pursuit of bad faith claims which had already been decided in prior cases justified an enhanced award of attorneys’ fees to the defendant. (Id. at 398, 402–03). The Windels sued the Borough to challenge the validity of access easements on their property. (Id. at 396). The superior court dismissed the majority of the Windels’ claims on res judicata grounds, finding the claims either were raised or could have been raised in one of the Windels’ four prior suits relating to the easements. (Id.). The superior court also awarded the Borough 80% of its actual attorneys’ fees because the Windels’ claims had been brought in bad faith. (Id. at 397). On appeal, the Windels argued that res judicata did not apply to the dismissed claims because neither the privity requirement nor the same cause of action requirement had been met. (Id.). The supreme court affirmed the lower court’s decision, noting that the Windels had voluntarily dismissed their appeal of a prior case whose res judicata holding they had initially challenged. (Id. at 398). Because the prior res judicata holding was unchallenged, the privity requirement had already been established, and the Windels could not now challenge the res judicata effect of the prior suit. (Id.). Additionally, the court noted that an enhanced award of attorneys’ fees for the Borough was justified because the Windels’ claims had already been adjudicated in previous cases and were therefore brought in bad faith. (Id. at 402–03). Affirming the lower court’s decision, the supreme court held that (1) an unchallenged res judicata judgment in a prior case bound the parties in the current proceeding and (2) a plaintiff’s pursuit of bad faith claims which had already been decided in prior cases justified an enhanced award of attorneys’ fees to the defendant. (Id. at 398, 402–03).

Windel v. Matanuska-Susitna Borough

CIVIL PROCEDURE

Clara Nieman

In Windel v. Matanuska-Susitna Borough, 496 P.3d 392 (Alaska 2021), the supreme court held that (1) an unchallenged res judicata judgment in a prior case bound the parties in the current proceeding and (2) a plaintiff’s pursuit of bad faith claims which had already been decided in prior cases justified an enhanced award of attorneys’ fees to the defendant. (Id. at 398, 402–03). The Windels sued the Borough to challenge the validity of access easements on their property. (Id. at 396). The superior court dismissed the majority of the Windels’ claims on res judicata grounds, finding the claims either were raised or could have been raised in one of the Windels’ four prior suits relating to the easements. (Id.). The superior court also awarded the Borough 80% of its actual attorneys’ fees because the Windels’ claims had been brought in bad faith. (Id. at 397). On appeal, the Windels argued that res judicata did not apply to the dismissed claims because neither the privity requirement nor the same cause of action requirement had been met. (Id.). The supreme court affirmed the lower court’s decision, noting that the Windels had voluntarily dismissed their appeal of a prior case whose res judicata holding they had initially challenged. (Id. at 398). Because the prior res judicata holding was unchallenged, the privity requirement had already been established, and the Windels could not now challenge the res judicata effect of the prior suit. (Id.). Additionally, the court noted that an enhanced award of attorneys’ fees for the Borough was justified because the Windels’ claims had already been adjudicated in previous cases and were therefore brought in bad faith. (Id. at 402–03). Affirming the lower court’s decision, the supreme court held that (1) an unchallenged res judicata judgment in a prior case bound the parties in the current proceeding and (2) a plaintiff’s pursuit of bad faith claims which had already been decided in prior cases justified an enhanced award of attorneys’ fees to the defendant. (Id. at 398, 402–03).