Crockett v. C.A.G. Investments, Inc.
381 S.W.3d 793
| Ark. | 2011Background
- Crockett filed a reformation and quiet-title action against C.A.G. after Omni previously litigated similar claims in a prior quiet-title suit.
- C.A.G. asserted defenses including statute of limitations, laches, estoppel, waiver, res judicata, collateral estoppel, and sought Rule 11 sanctions.
- The circuit court granted summary judgment for C.A.G. on waiver, res judicata, and collateral estoppel, and Crockett was sanctioned under Rule 11 with fees awarded.
- This court previously affirmed a related circuit-court quiet-title judgment in favor of C.A.G., ruling Omni lacked standing to challenge deeds to Crockett.
- Crockett, as Omni’s president, chairman, and sole stockholder, participated in the prior litigation and did not assert an individual ownership claim at that time.
- The current suit sought quiet-title and related remedies on land previously adjudicated in favor of C.A.G., with Crockett arguing newly raised theories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars Crockett's second suit | Crockett | C.A.G. | Yes; claim preclusion bars Crockett's suit |
| Whether the court properly awarded attorney’s fees to C.A.G. | Crockett | C.A.G. | Yes; fees upheld as prevailing party in breach-of-contract action |
| Whether Rule 11 sanctions were proper against Crockett and counsel | Crockett | C.A.G. | Yes; sanctions affirmed for unwarranted claim and needless litigation |
Key Cases Cited
- Jones v. Nat'l Bank of Commerce of El Dorado, 207 Ark. 613 (1944) (estoppel and privity considerations in binding prior proceedings)
- Calvert Fire Ins. Co. v. Carpet Mart of Texarkana, 266 Ark. 477 (1979) (strict application of res judicata/privity expansions)
- Carrigan v. Carrigan, 218 Ark. 398 (1951) (extension of res judicata concepts to related parties)
- Wells v. Heath, 269 Ark. 473 (1980) (privity requirement for applying res judicata)
- Rose v. Jacobs, 231 Ark. 286 (1959) (privity and identity of interests in successor cases)
- McWhorter v. McWhorter, 344 S.W.3d 64 (2009) (two facets of res judicata: claim and issue preclusion)
- Mason v. State, 206 S.W.3d 869 (2005) (distinguishes res judicata/ collateral estoppel in state context)