Williamson v. Columbia Gas & Electric Corp.

Williamson (plaintiff) built a gas company, and Columbia Gas & Electric (defendant), to destroy a competitor, gained control of it and manipulated its affairs until Williamson was forced into bankruptcy. Williamson filed two federal antitrust suits over the same injuries: one against Columbia and others alleging a conspiracy, and a later one against Columbia alone. The second suit reached judgment first and was dismissed on the merits. Columbia then won summary judgment in the first suit on claim-preclusion grounds, and Williamson appealed, arguing the two suits were not substantially identical.

Whether a merits judgment for the defendant in one action precludes the plaintiff from maintaining a second action where the wrongful acts alleged and the damages claimed are substantially identical.