the . same party); Landry v. Luscher, 95 Wash.App. 779, 976 P.2d 1274, 1276 (1999) (stating the rule against claim splitting — i.e., claim preclusion-prohibits splitting of personal injury and property claims arising out of same transaction). There is at least a question whether issue preclusion was applicable in Fournier as arguably the “issue” of coverage for property damage was not actually litigated in the prior proceeding.. See Hunter v. City of Des Moines, 300 N.W.2d 121, 123 (Iowa 1981) (distinguishing “issue preclusion” — where the issue had to be actually raised and litigated in prior proceeding — from what we now call claim preclusion — where the issue - “could” have been tried in prior proceeding); Cruise v. Wendling Quarries, Inc., 498 N.W.2d 916, 920 (Iowa Ct.App.1993) (<HOLDING>); Am. Ins. Co. v. Messinger, 43 N.Y.2d 184, 401
holding that because of the nature of a state habeas proceeding a decision actually rendered should preclude an identical issue from being relitigated in a subsequent  1983 action if the state habeas court afforded a full and fair opportunity for the issue to be heard and determined under federal standards holding that burden was on nonmoving party to show issue was not litigated where moving party presented supreme court opinion showing issue had been litigated holding arbitration decision disallowing insurers coverage defense binding in subsequent personal injury action where the issue was actually litigated and decided in prior action holding common issue of fault was actually litigated in prior property damage suit and determined adversely to plaintiff and therefore fault could not be relitigated in subsequent per sonal injury action under issue preclusion holding that the doctrine of collateral estoppel bars readjudication of issues when 1 the prior suit resulted in judgment on the merits 2 identical issues are involved 3 the issue was actually litigated 4 the issue was actually determined and 5 the determination was necessary to the resulting judgment