Northeast Harbor Golf Club, Inc. v. Town of Mount Desert
Supreme Judicial Court of Maine · 1992 · Corporations
618 A.2d 225 (1992)
Updated
CorporationsRes judicataPrivityAdministrative reviewclaim preclusionreal parties in interestplanning boardzoning
Facts
Shepard Harris submitted a subdivision proposal to the Mount Desert Planning Board in 1988, and after the town amended its ordinance, the Board decided to review the application under the pre-amendment ordinance. In 1989, the Committee to Preserve the Integrity of the Northeast Harbor Golf Course appealed that ruling through the zoning board and then to the Superior Court, which affirmed the Board's ruling in August 1990; the Committee did not appeal further. In 1991, the Golf Club asked the Planning Board to reconsider the same ruling, but the Board again decided to apply the pre-amendment ordinance and approved the subdivision. The Golf Club then sought Rule 80B review, challenging the same ordinance-choice ruling previously litigated by the Committee.
Issue
Whether the doctrine of res judicata barred the Golf Club from seeking judicial review of the Planning Board's decision to apply the pre-amendment ordinance because the same issue had already been litigated to final judgment by the Committee. More specifically, the question was whether the Golf Club was the same party as, or in privity with, the Committee in the earlier action.
Rule
Res judicata applies when: (1) the same parties, or their privies, are involved; (2) a valid final judgment was entered in the prior action; and (3) the matters presented for decision were, or might have been, litigated in the prior action. In determining who is bound, the court looks beyond nominal parties to the real parties in interest, and privity exists when two or more persons have a mutual or successive relationship to the same rights of property, with substance controlling over form.
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Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Burlington, Vermont, the city planning commission ruled that a developer’s condominium application would be reviewed under an older land-use ordinance. A neighborhood preservation committee challenged that ruling through the available administrative appeal and then lost in superior court; the judgment became final. Six months later, Maple Crest Homeowners Association, whose members own homes abutting the same parcel and allege the same increased traffic, neighborhood-character, and view-related harms, filed a new court challenge to the ordinance-choice ruling.
Is the homeowners association’s later challenge most likely barred?
Explanation. Res judicata bars relitigation when there is a valid final judgment, the same matter was or could have been litigated, and the later action involves the same parties or their privies. The majority held that courts look beyond nominal parties to the real parties in interest, and privity exists where there is a mutual or successive relationship to the same rights of property, with substance controlling over form. Here, the association asserts the same kind of particularized injuries tied to the same parcel and ordinance-choice dispute, so privity is likely present. (Derived from Northeast Harbor Golf Club, Inc. v. Town of Mount Desert (1992).)