Cromwell v. County of Sac
Facts
The action was on four Sac County bonds of $1,000 each and four attached interest coupons of $100 each. In an earlier suit, Samuel C. Smith sued on earlier-maturing coupons from the same bonds, and judgment went for the county; the county offered proof that Cromwell was the real owner and beneficiary of that prior action. The findings in the earlier case showed illegality and fraud in the inception of the bonds and that the plaintiff there had not shown he gave value for the coupons. In this case, Cromwell offered to prove that he had received the bonds and coupons in suit before maturity for value, but the trial court excluded that evidence.
Issue
When a prior action between the same parties involved different coupons from the same bonds, does the earlier judgment estop the present plaintiff from proving that he took the bonds and coupons now sued on for value before maturity? Also, was evidence admissible to show that the earlier action, though brought in another name, was for Cromwell's sole use and benefit?
Rule
A judgment rendered on the merits bars a later action on the same claim as to all matters that were or could have been litigated. But when the later suit is on a different claim or demand, the prior judgment operates as an estoppel only as to matters actually in issue and determined in the first action; the inquiry is what point was actually litigated and decided, not what might have been litigated. Where the record does not itself show the precise issue determined, evidence may be used to identify the matter actually decided.
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