Aldape v. Akins

In Aldape v. Akins, 105 Idaho 254, 668 P.2d 130 (Ct. App. 1983), the Court addressed the Res judicata doctrine: "Claim preclusion" or true res judicata ... treats a judgment, once rendered, as the full measure of relief to be accorded between the same parties on the same "claim" or "cause of action.". . . When the plaintiff obtains a judgment in his favor, his claim "merges" in the judgment; he may seek no further relief on that claim in a separate action. Conversely, when a judgment is rendered for a defendant, the plaintiff's claim is extinguished; the judgment then acts as a "bar." ... Under these rules of claim preclusion, the effect of a judgment extends to the litigation of all issues relevant to the same claim between the same parties, whether or not raised at trial. Collateral estoppel or "issue preclusion" . . . bars the relitigation of issues actually adjudicated, and essential to the judgment, in a prior litigation between the same parties ....(Id. at 256, 668 P.2d at 132.) In Aldape, the Court adopted the approach of the RESTATEMENT (SECOND) OF JUDGMENTS 24 (1982) recognizing that claim preclusion does not require absolute identity of claims in the two proceedings before judgment in the prior suit precludes the second suit.