George Sutherland

“ Where, for example, a court in deciding a case has enunciated a rule of law, the parties in a subsequent action upon a different demand are not estopped from insisting that the law is otherwise, merely because the parties are the same in both cases. But a fact, question or right distinctly adjudged in the original action cannot be disputed in a subsequent action, even though the determination was reached upon an erroneous view or by an erroneous application of the law. ”

“ And in New Orleans v. Citizens' Bank, 167 U.S. 371, 396, 17 S.C.t. 905, 913 (42 L. Ed. 202) this court, speaking through Mr. Justice White, said:
'The estoppel resulting from the thing adjudged does not depend upon whether there is the same demand in both cases, but exists, even although there be different demands, when the question upon which the recovery of the second demand depends has under identical circumstances and conditions been previously concluded by a judgment between the parties or their privies.'
And see Myers v. International Co., 263 U.S. 64, 44 S.C.t. 86, 68 L. Ed. 165. ”

“ Bigelow on Estoppel (6th Ed.) p. 112. A determination in respect of the status of an individual upon which his right to recover depends is as conclusive as a decision upon any other matter. Clemens v. ”