Little v. Blue Goose Motor Coach Co.
Supreme Court of Illinois
178 N.E. 496 (Ill. 1931)
After Dr. Robert Little got into a car accident with a bus owned by Blue Goose Motor Coach Co. (defendant), Blue Goose sued Little for negligence over property damage to the bus, and a justice of the peace ruled for Blue Goose, finding Little's negligence caused the accident. Little separately sued for his own personal injuries from the same accident, and after his death his executrix (plaintiff) took over that suit, winning in the City Court of East St. Louis; the appellate court reversed on collateral estoppel grounds, since the earlier ruling had already established Little's own negligence caused the crash. The executrix appealed, arguing the two lawsuits involved different subject matter - one for property damage, hers for wrongful death - so the prior ruling shouldn't control.
Whether the doctrine of estoppel by verdict applies when the claims in two lawsuits are different, but the underlying factual issue is the same.