Williams v. Robinson

In an earlier suit between Robinson (defendant) and his wife, Robinson's counterclaim asserted that Williams (plaintiff) had committed adultery with his wife, which Williams denied in his answer. Williams then brought this separate suit against Robinson for libel and slander, alleging Robinson had falsely and maliciously accused him of adultery in that prior case. Robinson moved to dismiss, arguing Williams was required to have raised the defamation claim as a counterclaim in the earlier lawsuit.

Whether causes of action whose underlying facts and circumstances share no common point may be tried separately rather than being compulsory counterclaims.