River Park, Inc. v. City of Highland Park
Illinois Supreme Court
703 N.E.2d 883 (Ill. 1998)
Spatz & Company and River Park, Inc. (plaintiffs) wanted to develop land in the City of Highland Park (defendant) and claimed the City intentionally delayed final approvals to force them into foreclosure so it could buy the property cheaply. The plaintiffs first sued in federal court under 42 U.S.C. Section 1983 for due-process violations; that suit was dismissed with prejudice and affirmed on appeal. They then sued the City in Illinois state court on different legal theories -- tortious interference, breach of implied contract, and abuse of governmental power -- based on essentially the same underlying facts. The trial court dismissed the state suit as barred by res judicata, but the appellate court reversed because the legal theories differed from the federal case.
Whether, under Illinois law, res judicata bars a second lawsuit between the same parties when it arises from the same core group of operative facts as an earlier suit that reached final judgment, even though the plaintiffs assert different legal theories.