In Snyder v. Marken, a negligence action between automobile owners growing out of a collision which resulted in injuries to a third person as well as to the plaintiffs, a judgment in the action by the third person was held unavailable as a defense, upon the ground that parties to a judgment are not bound by it in subsequent controversies between each other unless they were adversaries in the other action wherein the judgment was entered, that is, unless there were issues as between the co-defendants in that action.
George D. Lantz,
Notes and Comments,
Res Judicata as Between Joint Tort-Feasors,
2 Wash. L. Rev.
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