The doctrine of collateral estoppel, or issue preclusion, does not require identity of the causes of action involved. The elements of collateral estoppel are: (1) an issue identical to the one litigated in the prior suit; (2) that the issue was actually litigated in the prior suit; (3) that resolution of the issue was necessary to the prior judgment; and (4) the same parties. Pierce v. Rummell, 535 So.2d 594, 596-97 (Ala. 1988); Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985); Wheeler v. First Ala. Bank of Birmingham, 364 So.2d 1190, 1199 (Ala. 1978). Dairyland was not a party to the Tallapoosa County action, and Reaves was not a party to Jackson's action against Dairyland.
`Where these elements are present, the parties are barred from relitigating issues actually litigated in a prior [action].'" Smith, 653 So.2d at 934 (quoting Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985)).'
Where these elements are present, the parties are barred from relitigating issues actually litigated in a prior [action]."' Smith, 653 So.2d at 934 (quoting Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985))."Biles v. Sullivan, 793 So.2d 708, 712 (Ala. 2000).
' " Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985). "This additional requirement, that the parties be the same in both actions, is known as the doctrine of mutuality of estoppel.
"Substantially identical" parties under Alabama law exist where the parties to both proceedings are "either the same, or in privity of estate, blood, or law with the original parties." Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985). Claim preclusion thus may be applied in Alabama to bar litigants who were not actual parties to the prior judgment only where the non-party had either: (1) a mutual or successive relationship to the same property rights as a party to the prior proceeding; or (2) substantially identical interests in the litigation and an actual opportunity to litigate in the prior proceeding.
"Where these elements are present, the former suit bars any later suit on the same cause of action, including issues that were or could have been litigated in the prior case." Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985). By way of showing the slight contrast, we note that our cases applying the doctrine of collateral estoppel, or issue preclusion, have required the following elements: (1) that an issue in a prior action was identical to the issue litigated in the present action; (2) that the issue was actually litigated in the prior action; (3) that resolution of the issue was necessary to the prior judgment; and (4) that the same parties are involved in the two actions. Dairyland Ins. Co., 566 So.2d at 726; see also Constantine v. United States Fidelity Guar. Co., 545 So.2d 750 (Ala. 1989).
"` Smith v. Union Bank Trust Co., 653 So.2d 933, 934 (Ala. 1995). "`Where these elements are present, the parties are barred from relitigating issues actually litigated in a prior [action].'" Smith, 653 So.2d at 934 (quoting Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985)).'
"Where these elements are present, the former suit bars any later suit on the same cause of action, including issues that were or could have been litigated in the prior case." Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985). "[T]his Court has . . . held that a dismissal with prejudice is an adjudication on the merits.
"Where these elements are present, the parties are barred from relitigating issues actually litigated in a prior suit." Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985). See also Biles v. Sullivan, 793 So.2d 708 (Ala. 2000).
In Alabama, a prior judgment may be accorded collateral estoppel effect if: (1) the issue involved in the prior proceeding was identical to the issue involved in the present proceeding; (2) the issue was "actually litigated" in the prior proceeding; (3) the resolution of the issue was necessary to the prior judgment; and (4) the parties in the present proceeding are the same as those involved in the prior proceeding. Lott v. Toomey, 477 So.2d 316, 319 (Ala. 1985). Factor number 2 is, of course, the issue before this Court.