What is the test for having a judgment in a personal injury action against a defendant?

"Whenever a judgment in one action is raised as a bar to a later action under [claim preclusion], the key issue is whether the same cause of action is involved in both suits. California law approaches the issue by focusing on the primary right at stake: if two actions involve the same injury to the plaintiff and the same wrong by the defendant then the same primary right is at stake even if in the second suit the plaintiff pleads different theories of recovery, seeks different forms of relief and/or adds new facts supporting recovery." ( Eichman v. Fotomat Corp . (1983) 147 Cal.App.3d 1170, 1174, 197 Cal.Rptr. 612.)