Mells v. Billops
In Mells v. Billops, 482 A.2d 759 (Del. Super. 1984), the Court held that res judicata barred the plaintiff's personal injury action where the plaintiff's first action for property damage was brought in a forum which lacked subject matter jurisdiction over the second action.
The court reasoned that the plaintiff "voluntarily chose a court of limited jurisdiction when he could have presented all his claims had he brought the original action in this Court." Id. at 761.