8
COOPER v. HARRIS
Opinion of the Court
Carolina makes two related arguments based on the Dick
son litigation: first, that the state trial court’s judgment
should have barred this case altogether, under familiar
principles of claim and issue preclusion; and second, that
the state court’s conclusions should cause us to conduct a
“searching review” of the decision below, rather than
deferring (as usual) to its factual findings. Reply Brief 6.
The State’s preclusion theory rests on an assertion
about how the plaintiffs in the two cases are affiliated. As
the State acknowledges, one person’s lawsuit generally
does not bar another’s, no matter how similar they are in
substance. See Taylor v. Sturgell, 553 U. S. 880, 892–893
(2008) (noting the “deep-rooted historic tradition that
everyone should have his own day in court”). But when
plaintiffs in two cases have a special relationship, a judgment against one can indeed bind both. See id., at 893–
895 (describing six categories of qualifying relationships).
The State contends that Harris and Bowser, the plaintiffs
here, are members of organizations that were plaintiffs in
Dickson. And according to North Carolina, that connection prevents the pair from raising anew the questions
that the state court previously resolved against those
groups. See Brief for Appellants 20–21.
But North Carolina never satisfied the District Court
that the alleged affiliation really existed. When the State
argued that its preclusion theory entitled it to summary
judgment, Harris and Bowser responded that they were
not members of any of the organizations that had brought
the Dickson suit. See 3 Record 1577–1582 (Defs. Motion
for Summary Judgment); 4 Record 101–106 (Pls. Opposition to Motion for Summary Judgment). The parties’
dueling contentions turned on intricate issues about those
groups’ membership policies (e.g., could Harris’s payment
of dues to the national NAACP, or Bowser’s financial
contribution to the Mecklenburg County NAACP, have
made either a member of the state branch?). Because of