## Facts

- Property owners along Slaterville Road in the Town of Caroline, Tompkins County, alleged a state-owned bridge over Six Mile Creek caused or worsened flooding on their properties.
- After flood damage from a July 11, 1976 storm, the owners sued the State in the Court of Claims for negligent design and construction of the bridge.
- Following a four-day trial with dueling expert testimony, the Court of Claims found the 1976 flooding resulted from an “act of God” and also found the bridge was designed and constructed in accordance with good engineering practice and prevailing standards.
- Judgment was entered for the State dismissing the 1976 negligence claims, and the owners did not appeal.
- Before the 1976-flood trial concluded, the owners filed new Court of Claims actions alleging the same bridge’s negligent design and construction caused personal injury and property damage from an October 28, 1981 flood.
- After the State prevailed in the 1976-flood cases, it moved for partial summary judgment in the 1981-flood cases to bar relitigation of negligent design and construction under collateral estoppel.
- The Court of Claims denied the motion, reasoning the earlier negligence finding was not necessary because the judgment also rested on an act-of-God finding.

## Issues

1. Whether the prior unappealed judgment in the 1976-flood litigation collaterally estopped the owners from relitigating the State’s negligence in the bridge’s design and construction in separate actions arising from the 1981 flood.
2. Whether a determination expressly made as an alternative, independently sufficient ground for judgment can be “necessary” for issue-preclusion purposes when it was fully litigated and decided.

## Decision

- The Appellate Division, Third Department reversed the order denying the State’s motion.
- The court held the bridge-design-and-construction negligence issue was identical in both sets of actions and had been actually litigated, squarely addressed, and specifically decided in the 1976-flood trial.
- The court held the owners had a full and fair opportunity to litigate that issue in the earlier action, including through expert proof, and they chose not to appeal the adverse determination.
- The court rejected the view that the prior negligence finding lacked preclusive effect merely because the judgment also relied on an act-of-God ground.
- The court granted the State partial summary judgment precluding relitigation of negligent design and construction, leaving other issues not previously determined for further proceedings.

## Legal Principles

- Collateral estoppel applies when (1) the identical issue was necessarily decided in the prior action and is decisive in the present action, and (2) the party to be precluded had a full and fair opportunity to contest the issue.
- An issue may be treated as “necessary” for issue-preclusion purposes when it was expressly decided after full litigation and constitutes an independent, sufficient ground supporting the prior judgment, even if the judgment also rests on another independent ground.
- Issue preclusion is applied to protect finality and to avoid inconsistent determinations, particularly where the earlier determination followed a full trial and the losing party did not seek appellate review.
- Preclusion is issue-specific; it bars relitigation of the determined issue (here, negligent design and construction) but does not automatically bar distinct theories or facts not adjudicated in the prior case.

## Conclusion

The Appellate Division held that the owners could not relitigate whether the bridge was negligently designed or constructed because that issue was fully tried and decided against them in the earlier, unappealed 1976-flood litigation, even though the earlier judgment also rested on an act-of-God finding.


Aldrich v. State, 110 A.D.2d 331, 494 N.Y.S.2d 662 (N.Y. App. Div. 3d Dep’t 1985)