Waterhouse v. Levine
Supreme Massachusetts
65 N.E. 822 (1903)
Relevant factsFree
Waterhouse (plaintiff) sued Levine (defendant) for breach of a credit-sale contract before the credit period had actually expired, and that first suit resulted in judgment for Levine solely because it was filed prematurely; after the credit period expired, Waterhouse refiled the same claim and won $336.04, and Levine argued the earlier judgment barred the second suit under claim preclusion.
IssueFree
Whether a judgment that was not rendered on the merits bars a subsequent action between the same parties on the same cause of action.