Aldrich v. State of New York
Supreme Court of New York, Appellate Division
494 N.Y.S.2d 662 (1985)
Property owners (plaintiffs) sued the State (defendant) for flood damage from a 1976 flood, alleging negligent bridge design; after a full trial with detailed expert testimony, the Court of Claims found the flood was an act of God and separately found the bridge conformed to good engineering practice, precluding negligence. The plaintiffs, unappealed on that judgment, later sued again for a different, 1981 flood on the same negligent-design theory, and the trial court denied the State's motion for partial summary judgment on issue-preclusion grounds, reasoning the earlier negligence finding was only an alternative, non-necessary basis for the first judgment.
Whether a court's direct consideration and specific decision of an alternative, independently sufficient basis for its decision precludes the losing party from relitigating that same issue against the same party.