Alpha Mechanical, Heating & Air Conditioning, Inc. v. Travelers Casualty & Surety Co. of America

In Alpha Mechanical, Heating & Air Conditioning, Inc. v. Travelers Casualty & Surety Co. of America (2005) 133 Cal.App.4th 1319, the Court discussed the doctrine of res judicata. The Court stated its goal is judicial economy, and "'"'precludes piecemeal litigation by splitting a single cause of action or relitigation of the same cause of action on a different legal theory or for different relief.'"' The doctrine has two aspects: the first is claim preclusion, otherwise known as res judicata, which 'prevents relitigation of the same cause of action in a second suit between the same parties or parties in privity with them.' The second is issue preclusion or collateral estoppel, which '"precludes relitigation of issues argued and decided in prior proceedings."' To determine whether claim preclusion bars another action or proceeding, courts look to whether the two proceedings involve the same cause of action." (Id., at pp. 1326-1327.) "In analyzing whether a second action or proceeding is barred by issue preclusion or collateral estoppel, we look to whether the 'decision in the initial proceeding was final and on the merits and the issue sought to be precluded from relitigation is identical to that decided in the first action and was actually and necessarily litigated in that action." (Alpha, supra, 133 Cal.App.4th at p. 1327.)