Short answer. Generally no, but the bar is narrower than people expect. In later litigation between the same parties, only what appears on the face of the earlier judgment to have been adjudged, or was actually and necessarily included in it, is treated as settled.
What the law says
(c) In any other litigation between the same parties or their successors in interest, that only is deemed to have been adjudged in a former judgment or final order which appears upon its face to have been so adjudged, or which was actually and necessarily included therein or necessary thereto
Rule 39, Section 47 — Effect of judgments or final orders. Read the full provision →
Two different bars, and this is the narrower one
The rule sets out more than one effect of a final judgment. Where the second case is on the same claim, the judgment is conclusive not only on what was decided but on any matter that could have been raised in relation to it. Where the second case is a different claim between the same parties, a narrower rule applies — and that is the one that governs when you are asking whether a single finding carries over.
What actually carries over
For that different-claim situation, the rule states that only what appears upon the face of the judgment to have been adjudged, or which was actually and necessarily included therein or necessary thereto, is deemed adjudged. Three ideas are doing the work. It must appear on the face of the judgment, or it must have been actually included, or it must have been necessary to the result. A finding the earlier court could have skipped without changing its outcome does not meet that test.
Why passing remarks do not bind anyone
This is why an observation in the body of an earlier decision usually cannot be pressed into service later. Courts say a great deal along the way; only some of it is load-bearing. If the earlier judgment would have come out exactly the same without the finding, the finding was not necessary to it, and the rule does not treat it as adjudged. The test is about what the result depended on, not about what the decision mentioned.
Who is bound
The rule reaches the same parties and their successors in interest, so the bar is not defeated simply by putting the claim in the name of someone who inherited or acquired the interest. If you are trying to establish that a point is closed, be ready to show the earlier judgment itself and to identify precisely where the finding sits in its reasoning — the specificity is the whole battle here.