Codefendant Collateral Estoppel

Thee Aguila, Inc. v. Century Law Group, No. B289452 (D2d1 July 2, 2019)

Landlord and Tenant were parties to an eminent domain proceeding brought by the LAUSD. As part of the judgment in that proceeding, the court decided the allocation of just compensation between them. Now, Landlord sued Tenants over the lease agreement, purporting to have the right to further adjustment. 

But Landlord is collaterally estopped from doing so, because the allocation issue was decided in the prior case. The fact that both Landlord and Tenant were on the same side of the v. in the prior case doesn’t preclude the application collateral estoppel. Because the parties in the prior case don’t necessarily need to be adverse, the issue just needs to be decided against the party to be estopped.

Affirmed.