Caton v. Trudeau’s Empirical Analysis
157 F.3d 1026 · 1998
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 39 later decisions — most recently June 2019 · most notably In Re: John W. Catt, Ii. Appeal Of: Shirley and Gerald Hash (2004), Spokane Railway Credit Union v. Endicott (In Re Endicott) (2000)
3 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Grogan v. Garner · Kawaauhau v. Geiger · 101 Ill. 2d 246 - Housing Authority for La Salle County v. Young Men's Christian Ass'n · Miller v. J.D. Abrams Inc. · 177 Ill. 2d 185 - Talarico v. Dunlap
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Illinois Supreme Court has not yet determined whether default judgments are entitled to the same preclu-sive effect under the doctrine of collateral estoppel as any other judgment, but it has noted that there is a split of authority on the issue with some courts giving default judgments limited preclusive effect. The Appellate Court of Illinois, however, recently has held that collateral estoppel may be applied to a default judgment provided no injustice results from the application. This very recent pronouncement by an Illinois appellate court forecloses Caton’s contention, and we thus must conclude that the doctrine of collateral estoppel may be applied to default judgments under Illinois law. For collateral estoppel to apply, a party must have had a full and fair opportunity to litigate the issue in the prior action and there must be no undue unfairness to the party estopped. Catón clearly had a full and fair opportunity to contest the issue in the state proceeding, and we find no injustice in applying the doctrine of collateral estoppel in this case. Catón was properly notified of the proceeding and, in fact, filed a notice of removal therein. After remand, however, Catón chose not to appear in the proceeding further, even though Trudeau sought actual and punitive damages in excess of $10 million for libel per se. Under these circumstances, it cannot be disputed that Catón had an opportunity to litigate. Catón does not contest that he received notice of the default, a”
1 later decision quote this exact passage“The Illinois Supreme Court has not yet determined whether default judgments are entitled to the same preclu-sive effect under the doctrine of collateral estoppel as any other judgment, but it has noted that there is a split of authority on the issue with some courts giving default judgments limited preclusive effect. The Appellate Court of Illinois, however, recently has held that collateral estoppel may be applied to a default judgment provided no injustice results from the application. This very recent pronouncement by an Illinois appellate court forecloses Caton’s contention, and we thus must conclude that the doctrine of collateral estoppel may be applied to default judgments under Illinois law. For collateral estoppel to apply, a party must have had a full and fair opportunity to litigate the issue in the prior action and there must be no undue unfairness to the party estopped. Catón clearly had a full and fair opportunity to contest the issue in the state proceeding, and we find no injustice in applying the doctrine of collateral estoppel in this case. Catón was properly notified of the proceeding and, in fact, filed a notice of removal therein. After remand, however, Catón chose not to appear in the proceeding further, even though Trudeau sought actual and punitive damages in excess of $10 million for libel per se. Under these circumstances, it cannot be disputed that Catón had an opportunity to litigate. Catón does not contest that he received notice of the default, a”
1 later decision quote this exact passage“the defendant fails to appear for trial after having appeared and participated in earlier stages of the litigation ... the doctrine of collateral estoppel may be applied because courts believe that a defendant should not be permitted to end-run the finality of the judgment simply by not showing up for trial”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.