RUBEN A. SEBASTIAN,
v.
THE CITY OF MIAMI,

Fla. 3d DCA | 2020-10-14
No. 19-2410
Florida District Court of Appeal, Third District (2020) Negative Treatment
Cited by 323 cases


Opinion of the Court
Gordo

PER CURIAM.

“When a case involves a prior federal court judgment, Florida courts apply principles of federal claim preclusion in determining whether the Florida claim is res judicata.” Southern Coatings, Inc. v. City of Tamarac, 916 So. 2d 19, 21 (Fla. 4th DCA 2005) (citation omitted). “The law is well settled that when a fact, an issue, or a cause of action has been decided by a court of competent jurisdiction, neither of the parties involved shall be allowed to call into question and relitigate the thing decided, so long as the judgment or decree stands unreversed.” AGB Oil Co. v. Crystal Expl. & Prod. Co., 406 So. 2d 1165, 1167 (Fla. 3d DCA 1981) (citing Gordon v. Gordon, 59 So. 2d 40 (Fla. 1952); Simco Operating Corp. v. City Nat’l Bank of Miami Beach, 341 So. 2d 232 (Fla. 3d DCA 1976)).

Moreover, “the findings of a federal district court are binding on a state trial court under principles of collateral estoppel. The doctrine of collateral estoppel prevents identical parties from relitigating the same issues that have already been decided.” E.I. DuPont de Nemours & Co., Inc. v. Melvin Piedmont Nursery, 971 So. 2d 897, 898 (Fla. 3d DCA 2007).

Affirmed.


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Citator

Cited By (161 total)

  • State v. Antoine L. McBRIDE, 848 So. 2d 287 (Fla. 2003)
    …e, and concur only in the result. Collateral estoppel now has the identical components which have historically existed only for application of res judicata. . See Sheam v. Orlando Funeral Home, Inc., 88 So. 2d 591, 594 (Fla.1956); Gordon v. Gordon, 59 So. 2d 40, 44 (Fla.1952); Green v. State Dep't of Health & Rehabilitative Servs., 412 So. 2d 413, 414 (Fla. 3d DCA 1982) (“Where the causes of action are different, the doctrine of estoppel by judgment comes into play ....”) (quoting 32 Fla. Jur.2d, Judgments…
  • Topps v. State, 865 So. 2d 1253 (Fla. 2004)
    …collateral estoppel bars relitigation of the same issues between the same parties in connection with a different cause of action. See Clean Water, Inc. v. State Dep’t of Envtl. Reg., 402 So. 2d 456, 458 (Fla. 1st DCA 1981) (citing Gordon v. Gordon, 59 So. 2d 40, 44 (Fla.1952) (finding that “the principle of estoppel by judgment is applicable where the two causes of action are different, in which case the judgment in the first action only estops the parties from litigating in the second action issues — that…
  • R.J. Reynolds Tobacco Co. v. Matilde C. Martin, 53 So. 3d 1060 (Fla. 1st DCA 2010)
    …necessarily meant issue preclusion rather than claim preclusion — both of which are included in the concept of “res judicata”— because “factual issues and not causes of action were decided in Phase I.” Id. at 1333. Then, relying on Gordon v. Gordon, 59 So. 2d 40 (Fla.1952), and Seaboard Coast Line R.R. Co. v. Industrial Contracting Co., 260 So. 2d 860 (Fla. 4th DCA 1972), the court concluded individual Engle plaintiffs may only use the Phase I findings to establish elements of their claims in federal court…

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