## Facts

- Connie Hindmarsh and Martin L. Mock were involved in an automobile accident.
- Hindmarsh sued Mock in Idaho small-claims court for property damage from the accident and obtained a $3,000 judgment.
- About one year later, Hindmarsh filed a separate district-court action against Mock seeking damages for personal injuries allegedly caused by the same accident, including a shoulder injury that later required surgery.
- Mock moved for summary judgment, arguing the district-court action was barred by res judicata (claim preclusion) based on the small-claims judgment.
- Hindmarsh argued res judicata required identity of issues and that the earlier case involved only property damage; she also argued her personal-injury claim was not ripe until later medical treatment.

## Issues

1. Whether a final Idaho small-claims judgment can have claim-preclusive effect in a later district-court action arising from the same transaction.
2. Whether Hindmarsh’s later personal-injury suit was barred because it arose from the same automobile accident that was the subject of her earlier small-claims property-damage judgment.

## Decision

- The Idaho Supreme Court reversed the Idaho Court of Appeals and affirmed the district court’s grant of summary judgment to Mock.
- The court held there is no special exception preventing claim preclusion from applying to small-claims judgments.
- The court held Hindmarsh’s personal-injury action was barred because it arose from the same transaction (the accident) and was a claim that could have been brought in the earlier action.

## Legal Principles

- Claim preclusion bars subsequent actions between the same parties on the same claim and on claims arising from the same cause of action that were or could have been raised in the prior action.
- Small-claims judgments, if final, are treated as final judgments for claim-preclusion purposes absent a recognized exception.
- Claim preclusion focuses on whether the later claim arises from the same transaction or occurrence, not on strict identity of issues (which is characteristic of issue preclusion).
- Policy favoring finality supports applying claim preclusion to small-claims judgments, even though small-claims courts are designed as informal, low-cost forums.

## Conclusion

The Idaho Supreme Court held that a final small-claims judgment has full claim-preclusive effect and barred a plaintiff who recovered small-claims property damages from later pursuing a separate district-court personal-injury action arising out of the same automobile accident.


Hindmarsh v. Mock, 57 P.3d 803 (Idaho 2002)