Argued: July 19, 2018
Zachary J. Smith, Esq. (orally), Lawsmith Legal Services,
LLC, Bangor, for appellant Eric Ring
G. Mundhenk, Esq. (orally), Mundhenk & Bell, LLC,
Portland, for appellee Daniel Leighton
SAUFLEY, C.J., and ALEXANDER, MEAD, GORMAN, JABAR, HJELM, and
On February 8, 2016, Clinton McGaw, driving a vehicle owned
by Eric Ring, was on his way to pick up a customer in
furtherance of Ring's business when he was involved in a
collision with a vehicle driven by Daniel Leighton. In a
small claims matter filed by Leighton against McGaw, the
District Court (Lincoln, Stitham, J.) found that
McGaw was negligent and awarded Leighton just over $3, 900 in
damages and costs. No appeal was filed and the judgment was
paid. Ring then filed a complaint in the Superior Court
asserting that Leighton was negligent and had caused
Ring economic harm. Ring appeals from a summary judgment
entered by the Superior Court (Penobscot County, A
Murray, J.) in favor of Leighton on Ring's
complaint. Ring contends that the court erred in applying the
common law doctrine of res judicata to the earlier small
claims judgment obtained by Leighton against McGaw and
thereby determining that the judgment conclusively resolved
the issue of which driver was at fault.
In this matter of first impression, we conclude that claim
preclusion cannot, because of the unique limitations of small
claims procedure, operate to bar a subsequent suit brought in
District or Superior Court by a person who was not an actual
party to the small claims action, but rather was at most in
privity with the defendant in the small claims case.
Accordingly, we vacate the summary judgment and remand for
further proceedings in the trial court.
The facts are drawn from the summary judgment record, taken
in the light most favorable to Ring as the nonprevailing
party. See Estate of Frye v. MMG Ins. Co., 2018 ME
44, ¶ 8, 182 A.3d 158. Following the accident between
McGaw and Leighton, Leighton filed a small claims action
against McGaw in the District Court (Lincoln). Leighton's
statement of claim, seeking $3, 795.57 in damages plus costs,
alleged that McGaw had negligently caused the accident.
At the hearing on Leighton's claim, Ring's insurer
provided McGaw with counsel and a defense; Ring attended and
spoke to McGaw and McGaw's counsel. The court found that
McGaw was at fault in the accident and entered judgment in
favor of Leighton in the full amount that he had requested-
$3, 795.57, plus $106.30 in costs. The judgment did not make
any findings regarding Ring, or McGaw's relationship to
Ring. A satisfaction of judgment was filed on November 17,
In January 2017, Ring filed a negligence complaint against
Leighton in the Superior Court seeking unspecified damages,
alleging that Leighton, not McGaw, had been at fault in the
accident. Leighton's answer denied the substantive
allegations of the complaint and asserted as defenses, inter
alia, that Ring's claim was barred by the doctrines of
res judicata and bar and merger. Leighton then filed a
third-party complaint against McGaw seeking indemnification
if he were found to be liable to Ring, asserting that the
small claims judgment established McGaw's negligence.
In July 2017, Leighton moved for summary judgment "based
upon the fact that responsibility for [the] accident was
previously adjudicated in the Lincoln District Court."
Ring opposed the motion, arguing that the small claims
judgment had no res judicata effect as to him, in part
because he was not a party to that action. Following a
nontestimonial hearing, the court granted Leighton's
motion and entered a summary judgment, concluding that
"the issue of fault for the accident in question has
already been determined by a prior final judgment in the 2016
Small Claims proceeding," and that "Ring had a fair
opportunity and incentive to litigate the issue in a prior
proceeding." (Quotation marks omitted). The court
concluded that "collateral estoppel precludes Ring from
relitigating the factual issue of who was at fault for the
accident[;] . . . [t]herefore, Ring cannot establish that
Leighton breached a duty to him, and therefore cannot
establish all the necessary elements of a prima facie case
for negligence." Ring appealed.
In the ordinary case, the claim preclusion prong of the res
judicata doctrine "prohibits relitigation of an entire
cause of action between the same parties or their privies,
once a valid final judgment has been rendered in an earlier
suit on the same cause of action." Pushard v.
Bank of Am., N.A., 2017 ME 230, ¶ 19, 175 A.3d 103
(quotation marks omitted). We have not previously addressed
the situation presented here, where the person filing suit in
the Superior Court subsequent to the entry of judgment in the
small claims case-based on the same core set of facts-was not
a party in the small claims proceeding.
Leighton, as the party asserting the affirmative defense of
res judicata, bears the burden of proving its applicability.
See M.R. Civ. P. 8(c); ABNAMRO Mort. Gp. v.
Willis, 2003 ME 98, ¶ 5, 829 A.2d 527. "We
review the supported facts in the summary judgment record in
the light most favorable to [Ring], as the nonprevailing
party, to determine de novo if any genuine issue of material
fact exists for trial and whether, based on the undisputed
facts, [Leighton] was entitled to a judgment as a matter of
law." Estate of Frye, 2018 ME 44, ¶ 8, 182
A.3d 158. Likewise, "[w]e review decisions regarding the
effect of a prior judgment on a present action, which is a
question of law, de novo." Thibeault v.
Brackett, 2007 ME 154, ¶ 7, 938 A.2d 27.
Ring contends that the court erred in granting Leighton
summary judgment because, for two reasons, the small claims
judgment in Leighton's favor did not have preclusive
effect in the Superior Court: (1) the Small Claims Act, 14
M.R.S. §§ 7481-7487 (2017), requires that result;
and (2) Ring was not a party to the small claims action, nor
was he in privity with McGaw in that separate matter. If
fault for the accident is not established as a matter of law,
Ring reasons, then it remains a material fact in dispute and
summary judgment is precluded. See M.R. Civ. P.
56(c); Estate of Frye, 2018 ME 44, ¶ 8,
Because litigation of a small claim is unlike other civil
litigation in several important respects, before addressing
the merits of Ring's arguments we begin our analysis with
a review of the characteristics and limitations that make
"small claims proceedings . . . unique and different
from other proceedings conducted in the District Court."
Thomas v. BFC Marine/Bath Fuel Co., 2004 ME 27,
¶ 11, 843 A.2d 3.
Small claims proceedings are a creature of statute,
established by the Legislature with jurisdiction given to the
District Court "for the purpose of providing a simple,
speedy and informal court procedure for the resolution of
small claims." 14 M.R.S. § 7481. It is an
alternative, not exclusive, way to resolve a "small
claim," which is a claim presently subject to a
jurisdictional maximum of $6, 000,  exclusive of interest and
costs, that does not involve title to real estate. 14 M.R.S.
Pursuant to statute, "small claims proceedings are
governed by separate, succinct procedural rules" that we
have promulgated. Midland Funding LLC v. Walton,2017 ME 24, ¶ 16, 155 A.3d 864; 14 M.R.S. §
7484-A(1); see Maine Rules of Small Claims
Procedure. In keeping with the Legislature's directive
mandating simplicity and expediency, see 14 M.R.S.
§ 7481, those rules must be "construed to secure
the just, ...