Ms. Massengale was not called as a witness in the chiropractor's trial and claimed that she was not involved in the case at all.

The jury found that Ms. Massengale had not sustained any bodily injury and the trial court entered judgment in favor of State Farm.

Ms. Massengale also sued State Farm.

State Farm moved for summary judgment, arguing that the other court's decision barred Ms. Massengale's claims under the doctrines of res judicata and collateral estoppel.

The District Court's Decision

The court denied the motion.

In its decision, the court explained that, under applicable Michigan law, the doctrine of res judicata, or claim preclusion, barred a second action when (1) the prior action was decided on the merits, (2) both actions involved "the same parties or their privies," and (3) the matter in the second case was, or could have been, resolved in the first.

Here, the court found, the chiropractor, as an assignee of Ms. Masssengale, was not in "privity" with her such that both actions could be said to have involved "the same parties or their privies."

The court reasoned that, in light of the "limited scope" of Ms. Massengale's assignment of rights to the chiropractor to collect no-fault PIP benefits, the chiropractor and Ms. Massengale did not share a sufficient "identity of interests" to conclude that privity existed for purposes of her claim for no-fault PIP benefits, underinsured motorist benefits, and Medicare damages based on all of her medical bills and alleged injuries.

The court reached the same result with respect to the doctrine of collateral estoppel, or issue preclusion, which applies when, among other things, a party was a party or in privity to a party in the previous action.

The court reasoned that regardless of whether State Farm attempted to prove in the chiropractor's lawsuit that Ms. Massengale had not been injured at all by the motor vehicle accident, she had not had a "full and fair opportunity" to prove that she had been injured, and the chiropractor only was obligated to prove that her spine and neck had been injured in a manner that necessitated the need for its chiropractic services.

"[F]ull privity did not exist" between Ms. Massengale and the chiropractor for purposes of proving the issues of injury and causation and Ms. Massengale did not have "a full and fair opportunity to litigate" the issue of whether she was injured in the motor vehicle accident, the court concluded.

The case is Massengale v. State Farm Mutual Automobile Ins. Co., No. 2:18-CV-11366-TGB (E.D. Mich. Sept. 24, 2019).