The Anshun estoppel extends to cross-claims where the defendant's claim is intimately connected with the plaintiff's claim and arises substantially out of the same facts, notwithstanding the general observation in Tanning Research Laboratories that the principle will ordinarily not apply to cross-claims. Dissatisfaction with discovery in earlier proceedings does not constitute 'special circumstances' justifying departure from the Anshun rule, and a party cannot overcome perceived procedural difficulties in one court by instituting substantially similar claims in another court.
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