## Facts

- Beatrice M. Beegan received dental care from Dr. James L. Schmidt in Augusta, Maine, from spring 1975 through late fall 1976.
- Beegan alleged Schmidt failed to diagnose severe dental decay and gum deterioration, causing extensive later surgery, permanent tooth loss, pain and suffering, and related expenses.
- In September 1980, Beegan sued Schmidt asserting negligence and breach of implied warranty/implied contract arising from the same treatment.
- The Superior Court dismissed the 1980 action as untimely under Maine’s two-year malpractice statute of limitations.
- In November 1981, Beegan filed a new Superior Court action alleging breach of an express contract based on the same course of treatment and injuries.
- The Superior Court dismissed the 1981 action on res judicata grounds, and Beegan appealed.

## Issues

1. Whether dismissal of an action as time-barred constitutes a valid final judgment for purposes of claim preclusion.
2. Whether an express-contract claim based on the same dental treatment is barred by res judicata because it could have been asserted in the earlier malpractice action.

## Decision

- The Maine Supreme Judicial Court (Law Court) affirmed the dismissal of the 1981 action.
- The court held that a statute-of-limitations dismissal is a valid final judgment for res judicata purposes.
- The court held the express-contract suit was claim-precluded because it arose from the same transaction as the 1980 suit and could have been litigated in that action.

## Legal Principles

- Claim preclusion requires: (1) the same parties (or privies), (2) a valid final judgment in the prior action, and (3) a second action presenting matters that were or could have been litigated in the first action.
- A dismissal based on failure to comply with the statute of limitations constitutes a valid final judgment for res judicata.
- Under a transactional approach, all claims and theories of recovery arising from a single series of operative facts must be brought in one action; a later suit asserting a different theory (tort vs. contract, implied vs. express) is barred if it could have been asserted earlier.
- Res judicata prevents claim splitting and bars attempts to avoid an applicable limitations period by recasting the same factual dispute under a different legal label.

## Conclusion

Because the parties and operative facts were the same in both lawsuits, and because the first case’s limitations dismissal counted as a valid final judgment, the second express-contract action was barred by res judicata as a claim that could have been brought in the first action.


Beegan v. Schmidt, 451 A.2d 642 (Me. 1982)