[444]*444GILLETTE, J.
Plaintiff was injured and his car damaged in a collision with defendant Cold Box Manufacturing Company’s truck, driven by defendant Christenson. Plaintiff sued defendants in Multnomah County District Court to recover the property damage to his car. The jury, by a special verdict, found that defendants were negligent, that plaintiff was not negligent and that plaintiffs damages were $387.50. Plaintiff thereafter filed this circuit court action, seeking general and special damages totalling $41,210 for his personal injuries. The court granted defendants’ motion for summary judgment on res judicata grounds. It held that plaintiff had split his cause of action and that all of his claims arising from the. accident merged into the judgment in the property damage case. Plaintiff appeals; we reverse.
This case requires us to determine the extent to which the specific holding of a 50-year old Supreme Court opinion, based in part on a theoretical approach which that court has since abandoned, retains its precedential value. In Winters v. Bisaillon, 153 Or 509, 57 P2d 1095 (1936), the court held that actions for damage to the person and to property are distinct and that a judgment in one does not bar the maintenance of the other. It based its decision on Or Code 1930, § 1-811 (later OCLA § 1-911 and ORS 16.220), which permitted a plaintiff to “unite several causes of action” when they arose out of “[i]njuries both to the person and property, when caused by the same wrongful act or omission.” The court recognized that its decision was a minority position, as it continued to be afterwards, see Annots., 64 ALR 663, 62 ALR 2d 977, but it held that “the legislative intent in this state is clear that separate and distinct actions may be maintained.” 153 Or at 512.
The interpretation of “cause of action” which the court in Winters attributed to the legislature is based on the view that the substantive law may give a plaintiff a number of primary rights arising from a single act of defendant and that each of those primary rights constitutes a cause of action. One commentator, writing a decade before Winters, took this view in defining a cause of action as
“that group of operative facts which, standing alone, would show a single right in the plaintiff and a single delict to [445]*445that right giving cause for the state, through its courts, to afford relief to the party or parties whose right was invaded. The singleness of the right and delict is determined by a study of the old remedies in connection with which the concepts as to singleness of rights and delicts developed.” McCaskill, Actions and Causes of Action, 34 Yale LJ 614, 638 (1925). (Footnote omitted.)
Because the right to be free from bodily injury was not seen as the same as the right to be free from property damage, an invasion of each right created a separate cause of action, even if the invasions took place by the same act of the defendant. See Restatement (Second) Judgments, § 24 comment a. The statutory permission to join causes of action for personal injury and property damage in one lawsuit recognized, rather than altered, their status as separate causes of action.
The Supreme Court specifically rejected the McCaskill view of a cause of action only three years after Winters, at least in the context of determining whether an amended complaint substantially changed the original cause of action. Instead, the court adopted the transactional approach of Judge Charles Clark:
“The cause of action under the code should be viewed as an aggregate of operative facts which give rise to one or more relations of right-duty between two or more persons. The size of such aggregate should be worked out in each case pragmatically with an idea of securing convenient and efficient dispatch of trial business.” Clark, The Code Cause of Action, 33 Yale LJ 817, 837 (1924), quoted in Elliott v. Mosgrove, 162 Or 507, 545, 91 P2d 852, 93 P2d 1070 (1939).
Although Clark was concerned primarily with pleading problems, the Restatement of Judgments, § 62, adopted an approach similar to his for determining when a plaintiff had split a cause of action for res judicata purposes. It specifically required a plaintiff to unite personal injury and property damage claims arising from the same automobile accident. Restatement of Judgments, § 62, Illustration 1. The Restatement (Second) of Judgments, § 24(1) is even clearer, stating that a judgment extinguishes all claims against the defendant “with respect to all or any part of the transaction, or series of connected transactions, out of which the action arose.” The Reporter noted that this transactional view “comes close to Judge Clark’s conception.” Restatement (Second) Judgments, [446]*446§ 24, Reporter’s Note to comment a. The most important reason for the broadening definition of a cause of action is the ability under modern procedural systems for the plaintiff to combine claims of all kinds against the defendant in one action. There is no longer any benefit from dividing one set of events into artificial units. Restatement (Second) Judgments, Introduction, 5-10, and section 24, comment a.
The Oregon Supreme Court did not immediately apply the Clark definition of a cause of action to res judicata issues. However, in three cases beginning in 1975 it adopted the transactional approach of the Restatements and required that all claims arising out of a particular set of factual circumstances be brought in a single action. Rennie v. Freeway Transport, 294 Or 319, 656 P2d 919 (1982); Troutman v. Erlandson, 287 Or 187, 598 P2d 1211 (1979); Dean v. Exotic Veneers, Inc., 271 Or 188, 531 P2d 266 (1975). Although the court had also reaffirmed the holding of Winters v. Bisaillon, supra, as recently as 1971, Gaul v. Tourtellotte, 260 Or 14, 17, 488 P2d 416 (1971), the theoretical basis of its recent cases is inconsistent with Winters. The question is whether the court has impliedly overruled Winters.
If Winters were a common law decision, we would have no difficulty in saying that the recent Supreme Court cases have changed the common law so that Winters is no longer binding precedent. However, the Supreme Court explicitly based Winters on the legislature’s intent that there be separate actions for injury to the person and to property. If so, no judicial change in the common law can affect the legislature’s decision; we must await a legislative change or a Supreme Court redetermination of legislative intent. The Supreme Court’s interpretation of a statute is “a part of the statute as if written into it at the time of its enactment.” State v. Elliott, 204 Or 460, 465, 277 P2d 754 (1954), cert den 349 US 929 (1955).
Defendants point to certain legislative changes as indicating an alteration in the legislature’s view. In 1973, it amended ORS 16.220 to allow a plaintiff to join “several causes of action in the same complaint” when they all arose from “[t]he same transaction or transactions or occurrence.” Or Laws 1973, ch 59, § 1. However, it retained the language on which the Supreme Court had relied in Winters.
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[444]*444GILLETTE, J.
Plaintiff was injured and his car damaged in a collision with defendant Cold Box Manufacturing Company’s truck, driven by defendant Christenson. Plaintiff sued defendants in Multnomah County District Court to recover the property damage to his car. The jury, by a special verdict, found that defendants were negligent, that plaintiff was not negligent and that plaintiffs damages were $387.50. Plaintiff thereafter filed this circuit court action, seeking general and special damages totalling $41,210 for his personal injuries. The court granted defendants’ motion for summary judgment on res judicata grounds. It held that plaintiff had split his cause of action and that all of his claims arising from the. accident merged into the judgment in the property damage case. Plaintiff appeals; we reverse.
This case requires us to determine the extent to which the specific holding of a 50-year old Supreme Court opinion, based in part on a theoretical approach which that court has since abandoned, retains its precedential value. In Winters v. Bisaillon, 153 Or 509, 57 P2d 1095 (1936), the court held that actions for damage to the person and to property are distinct and that a judgment in one does not bar the maintenance of the other. It based its decision on Or Code 1930, § 1-811 (later OCLA § 1-911 and ORS 16.220), which permitted a plaintiff to “unite several causes of action” when they arose out of “[i]njuries both to the person and property, when caused by the same wrongful act or omission.” The court recognized that its decision was a minority position, as it continued to be afterwards, see Annots., 64 ALR 663, 62 ALR 2d 977, but it held that “the legislative intent in this state is clear that separate and distinct actions may be maintained.” 153 Or at 512.
The interpretation of “cause of action” which the court in Winters attributed to the legislature is based on the view that the substantive law may give a plaintiff a number of primary rights arising from a single act of defendant and that each of those primary rights constitutes a cause of action. One commentator, writing a decade before Winters, took this view in defining a cause of action as
“that group of operative facts which, standing alone, would show a single right in the plaintiff and a single delict to [445]*445that right giving cause for the state, through its courts, to afford relief to the party or parties whose right was invaded. The singleness of the right and delict is determined by a study of the old remedies in connection with which the concepts as to singleness of rights and delicts developed.” McCaskill, Actions and Causes of Action, 34 Yale LJ 614, 638 (1925). (Footnote omitted.)
Because the right to be free from bodily injury was not seen as the same as the right to be free from property damage, an invasion of each right created a separate cause of action, even if the invasions took place by the same act of the defendant. See Restatement (Second) Judgments, § 24 comment a. The statutory permission to join causes of action for personal injury and property damage in one lawsuit recognized, rather than altered, their status as separate causes of action.
The Supreme Court specifically rejected the McCaskill view of a cause of action only three years after Winters, at least in the context of determining whether an amended complaint substantially changed the original cause of action. Instead, the court adopted the transactional approach of Judge Charles Clark:
“The cause of action under the code should be viewed as an aggregate of operative facts which give rise to one or more relations of right-duty between two or more persons. The size of such aggregate should be worked out in each case pragmatically with an idea of securing convenient and efficient dispatch of trial business.” Clark, The Code Cause of Action, 33 Yale LJ 817, 837 (1924), quoted in Elliott v. Mosgrove, 162 Or 507, 545, 91 P2d 852, 93 P2d 1070 (1939).
Although Clark was concerned primarily with pleading problems, the Restatement of Judgments, § 62, adopted an approach similar to his for determining when a plaintiff had split a cause of action for res judicata purposes. It specifically required a plaintiff to unite personal injury and property damage claims arising from the same automobile accident. Restatement of Judgments, § 62, Illustration 1. The Restatement (Second) of Judgments, § 24(1) is even clearer, stating that a judgment extinguishes all claims against the defendant “with respect to all or any part of the transaction, or series of connected transactions, out of which the action arose.” The Reporter noted that this transactional view “comes close to Judge Clark’s conception.” Restatement (Second) Judgments, [446]*446§ 24, Reporter’s Note to comment a. The most important reason for the broadening definition of a cause of action is the ability under modern procedural systems for the plaintiff to combine claims of all kinds against the defendant in one action. There is no longer any benefit from dividing one set of events into artificial units. Restatement (Second) Judgments, Introduction, 5-10, and section 24, comment a.
The Oregon Supreme Court did not immediately apply the Clark definition of a cause of action to res judicata issues. However, in three cases beginning in 1975 it adopted the transactional approach of the Restatements and required that all claims arising out of a particular set of factual circumstances be brought in a single action. Rennie v. Freeway Transport, 294 Or 319, 656 P2d 919 (1982); Troutman v. Erlandson, 287 Or 187, 598 P2d 1211 (1979); Dean v. Exotic Veneers, Inc., 271 Or 188, 531 P2d 266 (1975). Although the court had also reaffirmed the holding of Winters v. Bisaillon, supra, as recently as 1971, Gaul v. Tourtellotte, 260 Or 14, 17, 488 P2d 416 (1971), the theoretical basis of its recent cases is inconsistent with Winters. The question is whether the court has impliedly overruled Winters.
If Winters were a common law decision, we would have no difficulty in saying that the recent Supreme Court cases have changed the common law so that Winters is no longer binding precedent. However, the Supreme Court explicitly based Winters on the legislature’s intent that there be separate actions for injury to the person and to property. If so, no judicial change in the common law can affect the legislature’s decision; we must await a legislative change or a Supreme Court redetermination of legislative intent. The Supreme Court’s interpretation of a statute is “a part of the statute as if written into it at the time of its enactment.” State v. Elliott, 204 Or 460, 465, 277 P2d 754 (1954), cert den 349 US 929 (1955).
Defendants point to certain legislative changes as indicating an alteration in the legislature’s view. In 1973, it amended ORS 16.220 to allow a plaintiff to join “several causes of action in the same complaint” when they all arose from “[t]he same transaction or transactions or occurrence.” Or Laws 1973, ch 59, § 1. However, it retained the language on which the Supreme Court had relied in Winters. In 1975, the [447]*447legislature again amended the statute to allow such joinder for “several causes of action and causes of suit[.]” Or Laws 1975, ch 158, § 1. In 1977, it repealed ORS 16.220 and replaced it with a provision allowing the plaintiff to join “as many claims, legal or equitable, as he has against an opposing party.” Or Laws 1977, ch 356, § 2 (codified as ORS 16.221). Finally, in 1979, it repealed ORS 16.221 in the enactment of the Oregon Rules of Civil Procedure. Or Laws 1979, ch 284, § 199. ORCP 24A, which governs the joinder of claims, is identical in substance to former ORS 16.221.
We find nothing in this history which indicates that the legislature changed its mind about what constitutes a cause of action or what, under present rules, constitutes a claim for relief. The 1973 and 1975 amendments retained the introductory language allowing a joinder of “several causes of action.” That language was part of the basis for the decision in Winters v. Bisaillon, supra. Allowing the joinder of multiple causes of action arising from one transaction is a very different thing from providing that the transaction itself determines the extent of the cause of action. The first accepts the McCaskill definition; the second accepts that of Clark and the Restatements. There is nothing in the 1977 change which indicates that the legislature intended to do more than provide a broader permissive joinder of claims, however they might be defined.
As the introduction and comments to the Restatement point out, one reason for the acceptance of the transactional basis of a cause of action is that modern procedural rules allow for broader joinder of claims than did older rules. The liberalization of Oregon’s joinder rules has had no impact on the issue in this case. A plaintiff in 1936 was just as able to join claims for personal injury and property damage from a single automobile accident as today. Because it was based on a statute rather than on the common law, and because we have no basis for holding that the legislature has changed the statute in a way significant to this issue, we hold that the rule of Winters v. Bisaillon, supra, remains the law of Oregon. A plaintiff may bring property damage and personal injury claims separately, and the trial court erred in ruling otherwise.
[448]*448Reversed and remanded.1