Peterson v. Newton
232 Ariz. 593
Ariz. Ct. App.2013Background
- Peterson and Fentzlaff were in a November 2008 auto accident; Peterson sued in small claims court for $2,500 and damages for vehicle and medical-related treatment.
- Small claims court awarded Peterson $2,500 (within the court’s jurisdiction) plus costs after trial.
- In November 2010, Peterson filed a superior court action seeking expenses and compensation for the same November 2008 accident.
- Fentzlaff moved to dismiss under claim preclusion; Peterson did not timely respond; superior court dismissed the case.
- Peterson argues the small claims judgment should not have claim preclusion effect; she also argues damages exceeded small claims’ jurisdiction.
- Court holds that, under Restatement and Arizona law, a plaintiff’s small claims judgment can bar later actions for the same claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does claim preclusion bar the later action here? | Peterson: small claims judgment should not bar later suit. | Fentzlaff: prior judgment on merits precludes the later suit. | Yes; claim preclusion bars the later action. |
| Is a small claims judgment binding under the Restatement for claim preclusion? | Peterson: Clusiau limits preclusion for small claims (issue preclusion only). | Fentzlaff: Restatement § 24 applies to all claims; judgment extinguishes claims. | Yes; Restatement § 24 supports preclusion of the same claim. |
| Should Clusiau v. Clusiau Enterprises control here regarding preclusion in small claims? | Peterson: Clusiau bars preclusion due to lack of appealability. | Fentzlaff: Clusiau does not control claim preclusion; it deals with issue preclusion and not this context. | No; Clusiau is distinguishable; not controlling for claim preclusion. |
| Does the fact that damages exceed small claims' jurisdiction affect preclusion? | Peterson: could not have brought the full personal injury claim in small claims. | Fentzlaff: strategic choice to use small claims is still subject to preclusion; jurisdictional limit doesn't bar the claim. | No; damages exceeding limit do not defeat preclusion if plaintiff chose small claims. |
Key Cases Cited
- Hall v. Lalli, 194 Ariz. 54 (Arizona Supreme Court 1999) (elements of claim preclusion: final judgment, same parties, same claim)
- Gila River Indian Community v. Bhayat, 212 Ariz. 64 (Arizona Supreme Court 2006) (restatement-based framework for claim preclusion)
- Clusiau v. Clusiau Enterprises, Inc., 225 Ariz. 247 (Arizona Court of Appeals 2010) (issue preclusion not controlling for small claims; distinguished from claim preclusion)
- Vincent v. Clean Water Action Project, 939 P.2d 469 (Colo.App. 1997) (judgment in limited jurisdiction precludes later litigation)
- Orselet v. DeMatteo, 206 Conn. 542 (Conn. 1988) (claim preclusion applies to subsequent personal injury actions)
- Hindmarsh v. Mock, 138 Idaho 92 (Idaho Supreme Court 2002) (preclusion applies to small claims adjudication)
- Bagley v. Bagley, 465 N.W.2d 551 (Iowa App. 1990) (same transaction supports claim preclusion)
- Doherty v. McMillen, 805 S.W.2d 361 (Mo. Ct. App. 1991) (small claims judgments can have claim preclusion effect)