Paramount Pictures Corporation, Appellant, v Allianz Risk Transfer AG et al., Respondents, et al., Defendant., 31 N.Y.3d 64

Summary

HOLDINGS: [1]-Federal preclusion law governed an analysis of whether res judicata applied to bar the assertion in a New York court of a claim that should have been raised as a compulsory counterclaim under Fed. R. Civ. P. 13 in a prior federal action between the same parties that included both a federal question and state-law causes of action; [2]-A transactional analysis applied under federal common law, requiring a determination of whether both actions sprang from the same transaction; [3]-Claim preclusion barred a lawsuit against investors alleging breach of a covenant not to sue because this claim was based on the same investment transaction as the prior federal action, it involved much of the same evidence, its essential facts were present in the first action, and it accrued immediately when the investors filed suit in the federal action and should have been asserted therein.