## Facts

- Beale struck Ferrer on the head, cracking Ferrer’s skull.
- Ferrer sued Beale for the battery and recovered monetary damages (later summaries report the award as £11).
- After that first case ended, Ferrer suffered a further physical development: a piece of his skull later came out of his head, claimed to be a result of the original blow.
- Ferrer filed a second lawsuit against Beale seeking additional damages for this later-manifested harm.
- The lower court ruled for Beale in the second action, and Ferrer appealed to the Court of King’s Bench.

## Issues

1. Whether a plaintiff who already recovered damages for a battery may bring a second action for additional injury later arising from the same battery.
2. Whether the first judgment operates as a bar to further recovery for later consequences traceable to the same tortious act.

## Decision

- The Court of King’s Bench affirmed judgment for Beale.
- The court held Ferrer could not maintain a second suit for additional damages flowing from the same battery after he had already recovered in the first action.
- The earlier recovery was treated as satisfying the claim for the injury caused by the blow, including later consequences.

## Legal Principles

- A single tortious act causing personal injury gives rise to one cause of action; the plaintiff may not split that cause of action into successive suits for different items of damage.
- In a personal-injury action, the plaintiff must seek all damages from the wrongful act in one case, including future harm that may later appear.
- Once a claim has been reduced to judgment (and treated as satisfied), the original cause of action merges into the judgment and is extinguished as a basis for later suits between the same parties for the same wrong.
- Later medical developments that stem from the same wound do not create a new claim; they are additional consequences of the same injury for which compensation should have been requested in the first action.
- The rule supports final resolution of disputes and prevents repeated litigation over the same battery as new effects of the injury become known.

## Conclusion

Ferrer v. Beale holds that after Ferrer recovered damages for Beale’s battery, he could not sue again when a further skull-related complication later appeared from the same blow; the law requires recovery for all resulting damages—present and future—in a single action, and the first judgment bars a later attempt to obtain more for the same tort.


Ferrer v. Beale, 91 Eng. Rep. 1361 (1701)