Parklane Hosiery Co. v. Shore
United States Supreme Court
439 U.S. 322 (1979)
Relevant factsFree
After the SEC obtained a declaratory judgment, following a nonjury trial affirmed on appeal, that Parklane's proxy statement was materially false and misleading, a separate stockholder plaintiff who had not participated in the SEC action sought partial summary judgment estopping Parklane from relitigating that same falsity issue in her own securities class action, and Parklane argued this offensive use of estoppel would improperly deny it a jury trial.
IssueFree
Whether a litigant who was not a party to a prior judgment may nonetheless use that judgment offensively to prevent a defendant from relitigating issues resolved in the earlier proceeding.