Strazza Building & Construction, Inc. v. Harris

Summary

The court held that the rebuttable presumption of privity applicable when a subcontractor seeks to relitigate matters resolved between a property owner and general contractor does not apply when a property owner seeks to bind a general contractor to a prior judgment against a subcontractor. Because the subcontractor's interests were materially narrower, the general contractor lacked a meaningful opportunity to litigate the broader issues, and the judgment addressed only part of the project, applying res judicata would be inequitable. The court therefore affirmed the denial of summary judgment.