Chicago Title Land Trust Co. v. Potash Corp. of Saskatchewan Sales Ltd.

Dist. Ct. did not err in granting defendants' motion to dismiss on ground of res judicata plaintiffs' action alleging breach of lease, breach of guaranty and fraud arising out of defendants-corporations' cancellation of commercial lease where plaintiffs' similar state-court fraud action against officers of same corporations had been dismissed with prejudice due to failure to state cause of action. State-court dismissal was tantamount to adjudication on merits, and both state-court action and instant lawsuit arose out of same alleged statements made by individual defendants on behalf of instant corporate defendants and concerned same issue as to whether corporate defendants had right to cancel instant lease. Fact that plaintiffs could not have sued instant individual defendants for breach of lease did not require different result or excuse plaintiffs from splitting instant claims where plaintiffs were required to bring into single lawsuit all claims against instant individual defendants and corporations arising out of alleged breach of lease.