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Lucky Brand Dungarees, Inc., et al. v. Marcel Fashions Group, Inc.

Paid petition · United States Court of Appeals for the Second Circuit, No. 17-0361-cv · judgment August 2, 2018


Decided · May 14, 2020
Pre-decision estimate: 3% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

In serial litigation between two parties, time­tested principles of claim preclusion and issue preclusion govern when parties may­and may not­ litigate issues that were, or could have been, litigated in a prior case. This Court has held that, in a subsequent case between the same parties involving different claims from those litigated in the earlier case, the defendant is free to raise defenses that were not litigated in the earlier case, even though they could have been. The Federal Circuit, Eleventh Circuit, and Ninth Circuit have all held the same in recent years. Their reasoning is straightforward: Claim preclusion does not bar such defenses, because the claims in the second case arise from different transactions and occurrences from the first case, and issue preclusion does not bar them either, because they were never actually litigated. The Second Circuit, however, has now held the opposite. Under the Second Circuit's "defense preclusion" rule, defendants are barred from raising such defenses even if the plaintiff’s claims are distinct from those asserted in the prior case and the defenses were never actually litigated. The question presented is: Whether, when a plaintiff asserts new claims, federal preclusion principles can bar a defendant from raising defenses that were not actually litigated and resolved in any prior case between the parties.

Counsel of record

For petitioner
Dale M. Cendali
Kirkland & Ellis LLP

For respondent
Michael B. Kimberly
McDermott Will & Emery LLP

Case

Conference history
Distributed for 3 conferences

Argument & decision

Argued January 13, 2020 — Dale Cendali · Michael B. Kimberly. Audio and transcript

Decided May 14, 2020. Opinion by Sotomayor.

Proceedings

  1. Jun 15 2020
    JUDGMENT ISSUED.
  2. May 14 2020
    Judgment REVERSED and case REMANDED. Sotomayor, J., delivered the opinion for a unanimous Court.
  3. Jan 13 2020
    Argued. For petitioners: Dale Cendali, New York, N. Y. For respondent: Michael B. Kimberly, Washington, D. C.
  4. Dec 12 2019
    Reply of petitioners Lucky Brands Dungarees, Inc., et al. filed. (Distributed)
  5. Dec 04 2019
    The record from the U.S.C.A. 2nd Circuit is electronically filed.
  6. Dec 03 2019
    Record requested from the U.S.C.A. 2nd Circuit.
  7. Nov 26 2019
    CIRCULATED
  8. Nov 12 2019
    Brief of respondent Marcel Fashions Group, Inc. filed.
  9. Nov 08 2019
    SET FOR ARGUMENT on Monday, January 13, 2020.
  10. Sep 11 2019
    Joint appendix filed.
  11. Sep 11 2019
    Brief of petitioners Lucky Brands Dungarees, Inc., et al. filed.
  12. Jul 18 2019
    Joint motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioners' brief on the merits is extended to and including September 11, 2019. The time to file respondent's brief on the merits is extended to and including November 12, 2019.
  13. Jul 12 2019
    Motion for an extension of time filed.
  14. Jun 28 2019
    Petition GRANTED.
  15. Jun 26 2019
    DISTRIBUTED for Conference of 6/27/2019.
  16. Jun 04 2019
    DISTRIBUTED for Conference of 6/20/2019.
  17. Jun 04 2019
    Reply of petitioners Lucky Brands Dungarees, Inc., et al. filed. (Distributed)
  18. May 31 2019
    Letter from counsel for petitioner waiving the 14-day waiting period under Rule 15.5 filed.
  19. May 31 2019
    Brief of respondent Marcel Fashion Group, Inc. in opposition filed.
  20. May 01 2019
    Motion to extend the time to file a response is granted and the time is extended to and including May 31, 2019.
  21. Apr 30 2019
    Motion to extend the time to file a response from May 1, 2019 to May 31, 2019, submitted to The Clerk.
  22. Apr 01 2019
    Response Requested. (Due May 1, 2019)
  23. Mar 27 2019
    DISTRIBUTED for Conference of 4/12/2019.
  24. Mar 06 2019
    Waiver of right of respondent Marcel Fashions, Inc. to respond filed.
  25. Feb 15 2019
    Petition for a writ of certiorari filed. (Response due March 25, 2019)
  26. Dec 10 2018
    Application (18A600) granted by Justice Ginsburg extending the time to file until February 15, 2019.
  27. Dec 07 2018
    Application (18A600) to extend the time to file a petition for a writ of certiorari from December 18, 2018 to February 15, 2019, submitted to Justice Ginsburg.