Uninsured motorist's fraud claim against State Farm is rejected on procedural grounds

In Sprague v. State Farm, the plaintiff attempted to sue State Farm for fraud.  He was an [apparently] uninsured motorist who was required to reimburse State Farm for collision damages expenses in a prior subrogation action.  The Court held that since his fraud claim arose out of the same transaction or occurrence, he was required to join the current claims in the original action brought by State Farm:  since he did not, he was precluded from bringing a separate action against State Farm later.