Collateral estoppel precludes a party from relitigating in a subsequent action or proceeding an issue clearly raised in a prior action or proceeding and decided against that party or those in privity, regardless of whether the courts or the causes of action are the same. Collateral estoppel allows the determination of an issue of fact or law raised in a subsequent action by reference to a previous judgment on a different cause of action in which the same issue was necessarily raised and decided.
Broder v. Pallotta & Assoc. Dev., Inc., NY Slip Op 04821 (2d Dep't September 2, 2020)
