Ryan v. New York Telephone Company

In Ryan v. New York Telephone Company (62 NY2d 494, 500, 467 N.E.2d 487, 478 N.Y.S.2d 823 [1984]), the Court of Appeals, held that: "The doctrine of collateral estoppel, a narrower species of res judicata, precludes a party from relitigating in a subsequent action or proceeding an issue clearly raised in a prior action or proceeding and decided against that party or those in privity, whether or not the tribunals or causes of action are the same." Two prerequisites must be met before collateral estoppel can be raised.