California, United States of America
The following excerpt is from California Coastal Com. v. Superior Court, 210 Cal.App.3d 1488, 258 Cal.Rptr. 567 (Cal. App. 1989):
"Under California law, res judicata applies not only to those claims actually litigated in a prior proceeding, but also to those which could have been litigated as part of that cause of action.... The fact that a plaintiff requests a different type of relief, or even presents a different legal theory, does not negate or lessen the binding effect of the previous state court judgment." (Id. at p. 1450; see also Hatch v. Bank of America (1960) 182 Cal.App.2d 206, 5 Cal.Rptr. 875.)
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