to codify case law as expressed in Neal v. Clark [, 95 U.S. 704, 24 L.Ed. 586 (1877),] which interp that state-court order of rescission based on finding of misrepresentation held to preclude relitigation of fraud issue in dischargeability proceeding). These decisions- in the bankruptcy context are consistent with general collateral estoppel principles, according to which an issue litigated in a legal action can be precluded in a subsequent equitable action, and vice versa. See Lytle v. Household Mfg., Inc., 494 U.S. 545, 556 n. 4, 110 S.Ct. 1331, 1338 n. 4, 108 L.Ed.2d 504 (1990) (noting that if certain claims had not been dismissed, jury’s determination would have had pre-clusive effect when court considered equitable claims); Parklane Hosiery, 439 U.S. at 334-37, 99 S.Ct. at 653-55 (<HOLDING>); Davenport v. DeRobertis, 844 F.2d 1310,
holding collateral estoppel elements met considering changed circumstances in the context of an exception to the general rule of collateral estoppel recognizing cause of action for equitable estoppel under erisa holding that collateral estoppel applies to  1983 claims holding equitable determination can have collateralestoppel effect in a subsequent legal action without violating seventh amendment holding that equitable determinationcan have collateral estoppel effect in subsequent legal action