Rios v. Davies case brief
Facts: Rios brought suit against Davis in District ct for damages alleged to have been sustained in a car accident which are personal injuries. Rios said proximate cause of injuries was negligent of defendant and Davis responds with contributory negligence. Also wanted res judicata and collateral estoppel in a suit between same parties in County Court. Res Judicata sustained and defendant won.
Earlier suit: Popular sued Davis for property damages from same car accident. Davis alleged contributory negligence and also joined Rios as 3rd party and sought to recover from Rios the $ for his own car. Jury found that Popular and Rios were guilty of negligence but also found Davis was guilty of negligence proximately causing collision so Popular lost against Davis and Davis lost against Rios.
Rios appeals saying that he can still bring suit because in that case, defendant won.
Reasoning: Judgment in previous suit did not litigate the cause of action that Davis brings, only found that Rios was negligent and that Davis’s negligence was not material there. Basically, the important point to remember is that the issue being precluded MUST be a significant issue in the previous suit. Outcome must have depended upon the findings. Right of appeal is from a judgment and not a finding