The Restatement Second of Judgments, published in 1982, echoes the position of the Restatement First of Judgments with respect to issue preclusion. (See Rest.2d Judgments (1982) § 27, com. o, p. 263.) The second Restatement does not appear to take an explicit position on the claim preclusive effect of a judgment affirmed on a non-merits ground, perhaps reflecting aversion to the terminology " 'on the merits[,]' " which has "possibly misleading connotations." (Id. , § 19, com. a, p. 161.) Regardless, the second Restatement conveys that in the absence of an appeal, a trial court "dismissal ... based on two or more determinations, at least one of which, standing alone, would not render the judgment a bar to another action on the same claim ... should not operate as a bar." (Id. , § 20, com. e, p. 172.) Nothing in the second Restatement suggests that if such a judgment is affirmed solely on grounds that would not trigger claim preclusion, the judgment should be imbued with claim preclusive effect.
*332The weight of more recent authority is in accord with these Restatements, at least with respect to cases in which an appeal has been taken. (See 18 Wright et al., Fed. Practice and Procedure: Jurisdiction & Related Matters (3d ed. 2016) § 4421, p. 619 ["The federal decisions agree with the Restatement view that once an appellate court has affirmed on one ground and passed over another, preclusion does not attach to the ground omitted from its decision"]; 18A Wright et al., supra , § 4432, p. 60 ["the nature of the ultimate final judgment in a case ordinarily is controlled by the actual appellate disposition"]; see also, e.g., Omimex Canada, Ltd. v. State, Dept. of Revenue (2015) 378 Mont. 490, 346 P.3d 1125, 1129-1130 ; Tydings v. Greenfield, Stein & Senior, LLP (2008) 11 N.Y.3d 195, 868 N.Y.S.2d 563, 897 N.E.2d 1044, 1046-1047 ; Beaver v. John Q. Hammons Hotels, L.P. (2003) 355 Ark. 359, 138 S.W.3d 664, 666-670 ; Stanton v. Schultz (Colo. 2010) 222 P.3d 303, 309 ;
**930Connecticut Nat. Bank v. Rytman (1997) 241 Conn. 24, 694 A.2d 1246, 1254 ; Humana, Inc. v. Davis (1991) 261 Ga. 514, 407 S.E.2d 725, 726-727 ; but see, e.g., Markoff v. New York Life Ins. Co (9th Cir. 1976) 530 F.2d 841, 842 [attempting to discern Nevada law].) Although most of these authorities concern issue rather than claim preclusion, their refusal to afford preclusive significance to a trial court determination that evades appellate review is informative.
C. Skidmore 's Continuing Vitality
1. Skidmore reflects a flawed view of preclusion
We agree with the weight of modern authority that Skidmore 's approach to preclusion is flawed.
Rules of claim and issue preclusion are, or at least should be, inextricably intertwined with rules of procedure. (See Rest.2d Judgments, supra , Introduction, pp. 5-13.) The law of preclusion reflects a view "that at some point arguable questions of right and wrong for practical purposes simply cannot be argued any more. It compels repose. In substituting compulsion for persuasion, the law of [preclusion] trenches upon freedom to petition about grievances and autonomy of action, very serious concerns in an open society." (Id. , at p. 11.) This finality "has to be accepted *454if the idea of law is to be accepted, certainly if there is to be practical meaning to the idea that legal disputes can be resolved by judicial process." (Ibid. ) But that does not mean finality should be embraced reflexively, nor attached to every decision rendered. "The 'chance' to litigate is not simply some unspecified opportunity for disputation over legal rights; it is the opportunity to submit a dispute over legal rights to a tribunal legally empowered to decide it according to definite procedural rules." (Id. , at pp. 6-7.) The less robust the *333process involved in resolving litigation the first time, the stronger the argument for permitting litigation once more. (Compare, e.g., Sanderson v. Niemann (1941) 17 Cal.2d 563, 110 P.2d 1025 [deeming small claims court too informal to support issue preclusion] with, e.g., Perez v. City of San Bruno (1980) 27 Cal.3d 875, 884-885, 168 Cal.Rptr. 114, 616 P.2d 1287 [more formal trial on appeal from small claims court judgment can support issue preclusion].)
The availability of a direct appeal reflects a sensible determination that the process culminating in a trial court's disputed decision is not sufficient to resolve litigation conclusively. Of course, a litigant's ability to secure appellate review may be waived or forfeited, as when a litigant fails to file a timely notice of appeal or fails to make an objection in the trial court. But when a litigant properly seeks appellate review of a ground underlying a trial court's determination, the fortuity that the judgment may be sustained on some other ground should not imbue the challenged ground with final and conclusive effect. The challenged ground is no more reliable-no more deserving of finality-merely because it need not be evaluated to resolve the appeal. (See Zevnik , supra , 159 Cal.App.4th at p. 85, 70 Cal.Rptr.3d 817.)
Recall, for example, the hypothetical breach of contract action in which the trial court concludes that no contract existed, and that even if a contract existed, the contract was not breached. (See ante , 234 Cal.Rptr.3d at p. 448, 419 P.3d at p. 925.) If an appellate court agrees that any existing contract was not breached-but does not consider whether any contract existed in the first place-it would be harsh indeed to bind the plaintiff to the trial court's "no contract" determination, preventing the plaintiff from suing the defendant on the contract even for subsequent conduct that clearly would constitute a material breach. Perhaps there was a contract, perhaps not. But the trial court's answer to that question should not be final merely because the judgment could be affirmed on another ground. Skidmore 's focus on the trial court's reasoning, however, is in tension with this conclusion.
Skidmore also is in tension with some of our other preclusion case law. We have repeatedly underscored the important role that the availability of appellate review plays in ensuring that a determination is sufficiently reliable to be conclusive in future litigation. We have, for example:
• Refused to give preclusive effect to a trial court's legal ruling on child custody issues presented by writ of habeas corpus, **931acknowledging that, "[s]ince an order denying an application for writ of habeas corpus is not appealable," finding preclusion would "wrongfully deprive[ ]" "the unsuccessful petitioner" "of custody until such time as he could allege a change in circumstances" ( In re Richard M. (1975) 14 Cal.3d 783, 790, 122 Cal.Rptr. 531, 537 P.2d 363 ); *334• Held that a finding made in connection with a cause of action should not have preclusive effect when the finding was adverse to the party that prevailed on *455that cause of action, in part because the party could not appeal (see Albertson v. Raboff (1956) 46 Cal.2d 375, 384-385, 295 P.2d 405 );
• Embraced a rule that an entity cannot be bound by a judgment as a privy, based on alleged control over the underlying litigation, if the entity lacks control over whether to take an appeal (see Minton v. Cavaney (1961) 56 Cal.2d 576, 581-582, 15 Cal.Rptr. 641, 364 P.2d 473 );
• Held that at least a certain type of issue preclusion might not attach to the decision of a private arbitrator, in part because "the arbitrator's errors must be accepted without opportunity for review" ( Vandenberg , supra , 21 Cal.4th at p. 832, 88 Cal.Rptr.2d 366, 982 P.2d 229 ); and
• Explained that, when evaluating the preclusive effect of an administrative determination, " '[t]he opportunity for judicial review of adverse rulings' is an important procedural protection against a potentially erroneous determination and is a factor to consider in determining whether collateral estoppel [ (that is, issue preclusion) ] applies. ( [Citation]; see also Rest.2d Judgments, § 28(1), p. 273 [issue preclusion will not apply if the party to be precluded could not, as a matter of law, obtain review].)" ( Murray v. Alaska Airlines, Inc. (2010) 50 Cal.4th 860, 875-876, 114 Cal.Rptr.3d 241, 237 P.3d 565.)2
The fundamental problem with Skidmore , then, is that it improperly gave effect to a trial court determination that evaded appellate review. Our opinion in the appeal preceding Skidmore considered only whether there had been a misjoinder of causes of action. We nevertheless held in Skidmore that the judgment at issue in the first case was "upon the merits," because of a trial court determination that we did not embrace on appeal. ( Skidmore , supra , 27 Cal. at p. 293.) More than a century later, and consistent with the modern approach to preclusion described above, we now conclude that a ground reached by the trial court and properly challenged on appeal, but not embraced by the appellate court's decision, should not affect the judgment's preclusive effect. This approach aligns far better with the recognition that although trial court decisions are often thorough, thoughtful, and correct, litigants should be afforded more procedural fairness before being bound by all aspects of a trial court's challenged determination.
Matar contends, however, that Skidmore properly reflects the principle that a trial court's judgment is presumptively correct. (See, e.g., *335Denham v. Superior Court (1970) 2 Cal.3d 557, 564, 86 Cal.Rptr. 65, 468 P.2d 193.) This argument confuses two concepts. It is true that a trial court's judgment is presumed correct, and so ordinarily will not be set aside on appeal absent an affirmative showing of reversible error. (See id. ; but see, e.g., Code Civ. Proc., § 128, subd. (a)(8) [stipulated reversals].) But that principle governs how appellate courts should review trial court determinations; it does not speak to the preclusive effect, in future litigation, of a challenged trial court determination that evaded appellate review. The distinction is particularly clear under California law: Although the presumption of correctness applies while direct review is ongoing (see *456Denham , at p. 564, 86 Cal.Rptr. 65, 468 P.2d 193 ), under California law, an unsatisfied trial court judgment has no preclusive effect until the appellate process is complete (see, e.g., Agarwal v. Johnson (1979) 25 Cal.3d 932, 954, 160 Cal.Rptr. 141, 603 P.2d 58 ; **932Brown v. Campbell (1893) 100 Cal. 635, 646-647, 35 P. 433 ).
Matar also argues that affording preclusive effect to a trial court's alternative (but ultimately unnecessary) determination would reduce litigation, thereby promoting judicial economy. We are not so sure. "While the rules of preclusion are supported in part by considerations of efficiency, affording the possibility of reconsideration is also a matter of efficiency, for it relaxes the requirements of procedural meticulousness in the first instance." (Rest.2d Judgments, supra , Introduction, p. 12.) To hold that an unreviewed alternative ground has preclusive effect "would put pressure on appellate courts to review alternative grounds as a matter of course ...." ( Zevnik , supra , 159 Cal.App.4th at p. 85, 70 Cal.Rptr.3d 817 [discussing issue preclusion].) Thus, "[a]ny benefit that might result from precluding" relitigation in future cases-cases "which may or may not arise"-"would come at the cost of increasing the burden on the appellate court in the initial action." ( Ibid. )
Nor is it clear that affording preclusive effect to such an alternative ground would protect parties from the burdens of litigation, as Matar also argues. If all unreversed trial court determinations must be given preclusive effect, then nonparties, armed with the issue preclusive effect of the trial court's unreviewed determination, may be encouraged to engage in litigation with the party bound by the effectively unappealable determination. (Cf. Vandenberg , supra , 21 Cal.4th at pp. 831-834, 88 Cal.Rptr.2d 366, 982 P.2d 229.)
In any event, our judicial system does not exist simply to resolve cases quickly, nor to prevent litigation from ever taking place. It is a serious matter whether a decision is correct in law and results from a fair process for all sides. Affording preclusive effect to a trial court determination that evades appellate review might speed up the resolution of controversies, but it would do so at the expense of fairness, accuracy, and the integrity of the judicial system. We decline to endorse that tradeoff. (Cf.
*336Johnson v. City of Loma Linda (2000) 24 Cal.4th 61, 77, 99 Cal.Rptr.2d 316, 5 P.3d 874 ( Johnson ) [refusing to give preclusive effect to a judgment based on laches, notwithstanding "the public policies of giving certainty to legal proceedings, preventing parties from being unfairly subjected to repetitive litigation, and preserving judicial resources"].)
We further observe that Matar's concerns about repetitive litigation are overstated. For one thing, if Matar had sought summary judgment on causation grounds when Nahigian did, Matar, too, would have had the benefit of the trial court's decision. Had Samara appealed, the judgment would not have been affirmed with respect to Matar simply because Samara's suit against Nahigian was untimely; the Court of Appeal would likely have confronted the merits of the trial court's no-causation ruling. In other words, Matar could have promoted judicial economy and protected himself from the burdens of further litigation simply by timely filing such a motion. (Cf. Love v. Waltz (1857) 7 Cal. 250, 252 ["If defendants had any doubt in regard to the right of plaintiff to sue, and wished to be protected from any further liability to Mrs. Love, they should have made her a party to the first suit, and then the judgment would have been conclusive upon all parties that could have any interest"].)
*457More generally, courts are not powerless to prevent a waste of judicial resources. Appellate courts can affirm on multiple grounds where appropriate. Trial courts can decline to reach issues that are unnecessary for judgment. And although, on remand, the trial court in this case should resolve Matar's motion for summary judgment without relying on the supposedly preclusive effect of the judgment in favor of Nahigian, the court need not forget or ignore the work it has already completed in this litigation. Declining to find preclusion does not require that a new judge be assigned and the case start afresh; it means only that a prior determination by itself does not necessarily, as a matter of law, bind the future one-and that the correctness of that future determination, if appealed, can be reviewed on its merits.
2. Stare decisis does not compel continued adherence to Skidmore
"[T]he doctrine of stare decisis" is "a fundamental jurisprudential policy that **933prior applicable precedent usually must be followed even though the case, if considered anew, might be decided differently by the current justices." ( Moradi-Shalal v. Fireman's Fund Ins. Companies (1988) 46 Cal.3d 287, 296, 250 Cal.Rptr. 116, 758 P.2d 58.) But the policy is just that-a policy-and it admits of exceptions in rare and appropriate cases. Factors that have contributed to our reconsideration of precedent include: "a ... tide of critical or contrary authority from other jurisdictions" ( *337Freeman & Mills, Inc. v. Belcher Oil Co. (1995) 11 Cal.4th 85, 100, 44 Cal.Rptr.2d 420, 900 P.2d 669 ); our precedent's "divergence from the path followed by the Restatements" ( Riverisland Cold Storage, Inc. v. Fresno-Madera Production Credit Assn. (2013) 55 Cal.4th 1169, 1179, 151 Cal.Rptr.3d 93, 291 P.3d 316 ); and our concern that no "satisfactory rationalization has been advanced" for the decision at issue ( Bernhard v. Bank of America (1942) 19 Cal.2d 807, 812, 122 P.2d 892 [overruling mutuality requirement for issue preclusion] ). As discussed, these rare factors are present here, as is tension between Skidmore and our other preclusion case law.
Moreover, several of the concerns that can give stare decisis particular force are not applicable in this case. When the party urging us to overrule a decision could have easily avoided the decision's effect, for example, we are less inclined to disturb our precedent. (See, e.g., Hernandez v. Restoration Hardware, Inc. (2018) 4 Cal.5th 260, 272, 228 Cal.Rptr.3d 106, 409 P.3d 281 [declining to overrule principle that nonparty class member cannot appeal, where other options meant that member would not be "discourage[d] ... from filing a meritorious appeal"]; cf. Kimble v. Marvel Entertainment, LLC (2015) --- U.S. ----, 135 S.Ct. 2401, 2408, 192 L.Ed.2d 463 [declining to overrule case that contracting "parties can often find ways around"].) Under Skidmore , however, a party that has lost in the trial court and has appealed the trial court's rulings can do little to ensure reversal of an adverse but ultimately unnecessary trial court determination.
Nor does Skidmore implicate the reliance concerns that have encouraged adherence to precedent in other contexts. We are particularly reluctant to overrule precedent when, unlike here, "[d]oubtless many people" have entered into transactions in reliance upon that precedent. ( Sacramento Bank v. Alcorn (1898) 121 Cal. 379, 382, 53 P. 813.) Although Skidmore might theoretically have induced some number of settlements following unsuccessful appeals, it is not the sort of "rule of property" that encourages strict adherence to precedent. ( *458Security Pacific National Bank v. Wozab (1990) 51 Cal.3d 991, 1000, 275 Cal.Rptr. 201, 800 P.2d 557.) Perhaps for this reason, no party has urged us to depart from "the general rule that a decision of a court of supreme jurisdiction overruling a former decision is retrospective in its operation," rather than purely prospective. ( County of Los Angeles v. Faus (1957) 48 Cal.2d 672, 680-681, 312 P.2d 680.)
Under all these circumstances, we conclude that People v. Skidmore , supra , 27 Cal. 287 should be-and is now-overruled. We caution, however, that we take no position on the significance of an independently sufficient alternative ground reached by the trial court and not challenged on appeal.
*338III. NEITHER CLAIM NOR ISSUE PRECLUSION SUPPORTS THE SUMMARY JUDGMENT IN FAVOR OF MATAR
Whether the trial court erred by granting Matar's motion for summary judgment is a question of law we review de novo. (See, e.g., Johnson , supra , 24 Cal.4th at pp. 67-68, 99 Cal.Rptr.2d 316, 5 P.3d 874.) We hold that it did. The critical point here is that the preclusive effect of the judgment in favor of Nahigian should be evaluated as though the trial court had not reached the causation issue. (See ante , Part II.C.) That premise implies that the causation issue was not "necessarily decided in the first suit," or even "decided" at all, rendering issue preclusion unavailable. ( DKN Holdings , supra , 61 Cal.4th at p. 825, 189 Cal.Rptr.3d 809, 352 P.3d 378.) Moreover, the Court of Appeal concluded, and Matar's briefing does not dispute, that a decision on timeliness grounds is not a decision "on the merits" in the relevant sense. Accepting that premise as undisputed (and without deciding its correctness), it follows that the ruling in favor of Nahigian was **934not a "final judgment on the merits," and that claim preclusion is likewise unavailable. ( DKN Holdings , supra , 61 Cal.4th at p. 824, 189 Cal.Rptr.3d 809, 352 P.3d 378.) Thus, neither claim nor issue preclusion can support the summary judgment entered in favor of Matar, and the trial court's ruling to the contrary was erroneous.
IV. DISPOSITION
We affirm the judgment of the Court of Appeal; overrule Skidmore , supra , 27 Cal. 287 ; and disapprove Bank of America v. McLaughlin etc. Co. , supra , 40 Cal.App.2d 620, 105 P.2d 607, to the extent it is inconsistent with this opinion.3
WE CONCUR:
CHIN, J.
CORRIGAN, J.
LIU, J.
CUÉLLAR, J.
KRUGER, J.
HOCH, J.*