J.S. v. Bethlehem Area School District

In J.S. v. Bethlehem Area School District, 794 A.2d 936 (Pa. Cmwlth. 2002), the Court provided a detailed description of res judicata and collateral estoppel. There, the Court stated: Res judicata encompasses two related, yet distinct principles: technical res judicata and collateral estoppel. Technical res judicata requires the coalescence of four factors: (1) identity of the thing sued upon or for; (2) identity of the causes of action; (3) identity of the persons or parties to the action; (4) identity of the quality or capacity of the parties suing or being sued ... Similarly, collateral estoppel bars a subsequent lawsuit where: (1) an issue decided in a prior action is identical to one presented in a later action; (2) the prior action resulted in a final judgment on the merits; (3) the party against whom collateral estoppel is asserted was a party to the prior action, or is in privity with a party to the prior action; (4), the party against whom collateral estoppel is asserted had a full and fair opportunity to litigate the issue in the prior action. Id. at 939.