Garcia

*1337 In an earlier action in which Florencia B. Garcia petitioned to dissolve her marriage to Juan J. Garcia (Dissolution Action), the family court *1338 found that Florencia did not meet her burden of establishing a valid marriage and quashed service as to Juan and dismissed the action. 1 Florencia then filed the underlying action in which she petitions for nullity of marriage (Nullity Action). In the Nullity Action, Juan appeals from two orders of the family court: (1) an order in which the court found that Florencia is the spouse or putative spouse of Juan and ruled that she may proceed with the claims in her petition (Putative Spouse Order); and (2) an order in which the court directed Juan to pay Florencia spousal support arrears, ongoing spousal support and attorney fees and costs (Support Order).

In challenging the two orders, Juan raises a single legal issue for review on appeal: Under the doctrine of res judicata, does the judgment in the Dissolution Action bar the relief Florencia seeks in the Nullity Action?

Because the Dissolution Action and the Nullity Action involve different primary rights, we affirm the Support Order. Because the Putative Spouse Order is not a…