FRCP
Where issues raised in a subsequent suit are compulsory counterclaims in a prior suit resulting in a default judgment, and the earlier decision is temporarily vacated for excusable neglect and then reinstated, claim preclusion bars the claims in the subsequent suit when the subsequent suit is administratively joined to the prior action and law of the case bars the claim if the caption numbers are joined.
http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2016/D01-27/C:15-2224:J:Easterbrook:aut:T:fnOp:N:1693131:S:0
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.