Alexander J. Walker, Jr. v. Aaron Day

Summary

The Supreme Court of New Hampshire held that the trial court erred by applying the First Circuit’s privity standard to a res judicata analysis and vacated the dismissal of the plaintiff’s conspiracy claim. The Court affirmed that under New Hampshire law a non‑party is bound by res judicata only if true privity exists, which co‑conspirators alone do not satisfy, and remanded for further proceedings.