Cambria v. Jeffery

After a car accident involving Cambria's servant and Jeffery, Jeffery first sued Cambria (plaintiff) for his own injuries, and though the court found Cambria's servant negligent too, it entered judgment for Cambria because Jeffery was found contributorily negligent. Cambria then sued Jeffery separately for damage to his own car; at trial the jury found for Cambria, but the judge entered judgment for Jeffery instead, reasoning the prior case had already established Cambria's servant was negligent, and Cambria appealed.

Whether issue preclusion bars relitigating a fact that was found in a prior action but was not actually necessary to that action's judgment.