Lucky Brand Dungarees, Inc., Petitioners v. Marcel Fashions Group, Inc.

Summary

The Supreme Court held that "defense preclusion" is not a separate doctrine of res judicata; claim preclusion bars a defense only when the later suit involves the same claim, i.e., a common nucleus of operative facts. Because the 2011 action involved different trademarks, conduct, and time, Lucky Brand could assert its release defense. The Court reversed the Second Circuit and remanded for further proceedings consistent with this holding.