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It did so by determining the Engle III court really meant issue preclusion rather than claim preclusion when it used the terms res judicata effect because factual issues and not causes of action were decided in Phase I. 78 The Brown court concluded that individual plaintiffs could rely on the res judicata findings only if they could demonstrate with a reasonable degree of certainty which facts were actually adjudicated during the Phase I trial

Brain Res Bull 1989

Nicotine is a fast-acting chemical that reinforces the brains reward system, she explains