โ Minneapolis Cmty. Dev. Agency v. Buchanan, 268 F.3d 562, 566 (8th Cir.2001). โCollateral estoppel is available where: (1) the issues are identical to those in a prior adjudication; (2) there was a final judgment on the merits; (3) the estopped party was a party or in privity with a party in the previous action; and (4) the estopped party was given a full and fair opportunity to be heard on the adjudicated issues.โ Id. (quoting Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 158โ59 (Minn.Ct.App.2001) ).Here, the district court determined that the Commissioner's order barred the ADA and RA claims because the Commissioner's order was, in the court's view, a final, unappealed decision entitled to preclusive effect.
Id. "Collateral estoppel is available where: (1) the issues are identical to those in a prior adjudication; (2) there was a final judgment on the merits; (3) the estopped party was a party or in privity with a party in the previous action; and (4) the estopped party was given a full and fair opportunity to be heard on the adjudicated issues." Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 158-59 (Minn.Ct.App. 2001). We find no error in the district court's application of the collateral estoppel doctrine.
Minnesota law does not require mutuality of all parties for the invocation of collateral estoppel. Mpls. Comm. Dev. Agency v. Buchanan, 268 F.3d 562, 566 (8th Cir. 2001) (citing Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 158-59 (Minn. Ct. App. 2001)). Therefore, the fact that Defendant Goodman was not a named party in the state court action does not preclude the application of issue preclusion.
"Collateral estoppel is available where: [i] the issues are identical to those in a prior adjudication; [ii] there was a final judgment on the merits; [iii] the estopped party was a party or in privity with a party in the previous action; and [iv] the estopped party was given a full and fair opportunity to be heard on the adjudicated issues." Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 158-59 (Minn.Ct.App. 2001). "Unpublished cases from [the Court of Appeals of Minnesota] are not precedential but may be persuasive."
Minnesota courts have stated that "collateral estoppel" is available where: (1) the issues are identical to those in prior adjudication; (2) there was a final judgment on the merits; (3) the estopped party was a party or in privity with a party in the previous action; and (4) the estopped party was given a full and fair opportunity to be heard on the adjudicated issues. Manion v. Nagin, 394 F.3d 1062, 1066 (8th Cir. 2005);Lyon Fin. Servs. Inc. v. Waddill, 625 N.W.2d 155, 158-59 (Minn.Ct.App. 2001). The elements necessary for application of "res judicata" are essentially the same.
Likewise, this court held in Lyon Fin. Servs., Inc. v. Waddill, that a motion to vacate a judgment filed two years after entry of that judgment was timely because "[d]efault judgments are to be liberally reopened to promote resolution of cases on the merits." 625 N.W.2d 155, 160 (Minn.App. 2001) (quotation omitted), rev. denied (Minn. June 19, 2001).
"Default judgments are to be liberally reopened to promote resolution of cases on the merits." Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 160 (Minn. App. 2001) (quotation omitted), review denied (Minn. June 19, 2001).
See In re Welfare of S.R.S., 756 N.W.2d 123, 128 (Minn. App. 2008) (recognizing that issue of subject-matter jurisdiction had not been fully and fairly litigated when "the question of jurisdiction was summarily addressed by the Colorado court in response to respondent's request for a status conference to clarify the issue of jurisdiction"), review denied (Minn. Dec. 16, 2008); Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 159-160 (Minn. App. 2001) (concluding that, despite "substantive ruling," the issue of personal jurisdiction was not fully and fairly litigated when hearing transcript did not reveal any substantive discussion of the jurisdictional issue), review denied (Minn. June 19, 2001); see also In re J.D.M.C., 739 N.W.2d 796, 808-09 (S.D. 2007) (stating that court could not review whether personal and subject-matter jurisdiction questions were fully and fairly litigated when record did not include transcript of the proceedings).
Jurisdiction is essential to a court's ability to adjudicate a claim, and any order issued in its absence is void. Matson v. Matson, 310 N.W.2d 502, 506 (Minn. 1981); Lyon Fin. Servs., Inc. v. Waddill, 625 N.W.2d 155, 158 n. 3 (Minn.App. 2001), review denied (Minn. June 19, 2001).
Hengel v. Hyatt, 312 Minn. 317, 318, 252 N.W.2d 105, 106 (1977); Peterson v. Eishen, 495 N.W.2d 223, 225 (Minn.App. 1993); see also Griffis v. Luban, 633 N.W.2d 548, 550 (Minn.App. 2001), 2001 WL 1035120, at *2 (Minn.App. Sept. 11, 2001) (stating that the determination of whether personal jurisdiction exists is a question of law, which this court reviews de novo). The enforcement of a foreign judgment in Minnesota is guided by the Full Faith and Credit Clause of the United States Constitution, which states that "[F]ull Faith and Credit shall be given in each State to the public Acts, Records, and judicial Proceedings of every other State." U.S. Const. art. IV, ยง 1; see also Lyon Fin. Servs. Inc. v. Waddill, 625 N.W.2d 155, 158 (Minn.App. 2001), review denied (Minn. June 19, 2001).