Does estoppel 3 bar a wife from a claim for general damages in a personal injury action arising from a motor vehicle accident?

San Francisco relies on Sanderson v. Niemann (1941) 17 Cal.2d 563, 110 P.2d 1025. The question in that case was whether a wife's claim for general damages in a personal injury action arising from an automobile collision was barred by the principle of estoppel ³ since her husband had previously sued for consequential damages in small claims court to recover losses suffered by the marital community as a result of the same accident. The court held that the wife's action was a separate cause of action, and that the small claims judgment had no estoppel effect on the issues of negligence and contributory negligence, essentially because of the informal procedures of the small claims court. (Id., at p. 575, 110 P.2d 1025.)