Chicago, R.I. & Pac. Ry. Co. v. Schendel - 270 U.S. 611 (1926)
U.S. Supreme Court
Chicago, R.I. & Pac. Ry. Co. v. Schendel, 270 U.S. 611 (1926)
Chicago, Rock Island & Pacific Railway Company v. Schendel
Nos. 683, 684
Argued March 17, 18, 1926
Decided April 12, 1926
270 U.S. 611
1. The effect of a judgment as res judicata between adverse parties is not dependent on the arrangement of the parties in the record or on which of them was the actor. P. 270 U. S. 615.
2. A judgment on the same cause of action may be availed of as a bar in an action pending in another jurisdiction which began before the one in which the judgment was recovered. Id.
3. A judgment fixing the compensation recoverable on account of the death of a railroad employee due to an accident in Iowa was rendered by an Iowa court in proceedings under the Iowa compensation act brought by the railroad, and was pleaded by the railroad in an action brought against it for the same cause in Minnesota under the Federal Employers' Liability Act. Held that both courts had jurisdiction to decide whether the deceased was engaged in intrastate or interstate commerce, and that the Iowa judgment, being the earlier one rendered, was res judicata in the other action, although the other was brought first. P. 270 U. S. 616.
4. Whenever an action may be properly maintained or defended by a trustee in his representative capacity without joining the beneficiary, the latter is bound by the judgment. P. 270 U. S. 620.
5. The question of identity of parties in two action is of substance; parties nominally the same may be in legal effect different, and parties nominally different may be in legal effect the same. Id.
6. Identity of parties exist between two proceedings to fix compensation or damages against a railroad for the accidental death of an employee, in one of which the state compensation law was invoked against the widow upon the ground that the deceased's employment was intrastate, while in the other the administrator sued under the Federal Employers' Liability Act upon the ground that it was interstate, the widow being the sole beneficiary in both cases. Troxell v. Delaware, etc. R. Co., 227 U. S. 434, distinguished. P. 270 U. S. 617.
7. A decision fixing compensation, under the Iowa statute, made by the Deputy Industrial Commissioner, acting by stipulation in lieu of a board of arbitration, but pending on appeal to the Commissioner, is not final, and could not be invoked a an estoppel in another action. P. 270 U. S. 623.
163 Minn. 460 reversed. Ibid., 457, affirmed.
Certiorari to judgments of the Supreme Court of Minnesota affirming judgments for damages in actions brought under the Federal Employers' Liability Act.