In a previous article titled, "The Collateral Effects of Article 78 Findings on Subsequent Civil Litigation," we discussed Article 78 of the CPLR as it pertained to collateral estoppel. Here, we analyze Article 78 judgments as they pertain to res judicata.
Williams v. Roberts,1 a 2012 Northern District case, demonstrates an emerging consensus concerning res judicata and Article 78 judgments. The court noted that res judicata barred claims for injunctive relief which involved the same transaction that was the subject of a previous Article 78 proceeding. In contrast, numerous cases have held that res judicata does not bar subsequent claims for damages even though they involved the same transaction.
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