Cited by

Day v. N.H. Retirement System, 138 N.H. 120, 122, 635 A.2d 493, 495 (1993); see also Morin v. J.H.

A department of labor hearing officer’s decision is “an adjudication as to the condition of the injured [employee] at the time it was entered,” Johnson v. Aetna Life & Casualty Co., 131 N.H. 698, 701, 559 A.2d 838, 840 (1989) (quotation and brackets omitted), and “is not a judgment as to the claimant’s future condition,” Morin v. J.H.

Valliere Co., 113 N.H. 431, 434, 309 A.2d 153, 155 (1973) (unappealed decision is a final judgment).

In its broadest sense, the term res judicata “cover[s] all the various ways in which a judgment in one action will have a binding effect in another.” Morin v. J.H.

Valliere Co., 113 N.H. 431, 434, 309 A.2d 153, 155 (1973); Restatement (Second) of Judgments § 27 (1982).

Valliere Co., 113 N.H. 431, 434, 309 A.2d 153, 155 (19(73) (res judicata may apply to unappealed decision of administrative agency).

reporter’s note 3, at 599-600, no issue has been raised here about the cognizability of a Canadian administrative judgment, as such, presumably because our domestic law accords preclusive effect to administrative judgments under the same conditions that apply to the judgments of a court, see Morin v. T. H. Valliere Co., 113 N.H. 431, 433-34, 309 A.2d 153, 155 (1973).

The superior court dismissed the plaintiff’s appeal on the ground that the April 15, 1986 decision by the Department had already found that Mr. Johnson had “light duty work capabilities.” The decision of that date was “an adjudication as to the condition of the injured workman at the time it [was] entered,” see Morin v. J. H. Valliere Co., 113 N.H. 431, 434, 309 A.2d 153, 155 (1973).

Morin v. J. H. Valliere Co., 113 N.H. 431, 434, 309 A.2d 153, 155 (1973); Household Goods Carriers v. Ouellette, 107 N.H. 199, 201, 219 A.2d 699, 700 (1966).

Res judicata applies to decisions of the labor commissioner.

“As a matter of principle it is absolutely clear that the reasons behind the doctrine of res judicata as developed in the court system are fully applicable to some administrative proceedings.” 2 K. Davis Administrative Law TREATISE § 18.02, at 548 (1958) (emphasis in the original); accord, Morin v. J.H.

Laconia Nat’l Bank v. Lavallee, 96 N.H. 353, 355, 77 A.2d 107, 108 (1950); Morin v. J. H. Valliere Co., 113 N.H. 431, 309 A.2d 153 (1973).