explaining that the doctrine of res judicata "is often analyzed ... to consist of two preclusion concepts: 'issue preclusion’ and ‘claim preclusion’ ”: "Issue preclusion refers to the effect of a judgment in foreclosing relitigation of a matter that has been litigated and decided. .... Claim preclusion refers to the effect of a judgment in foreclosing litigation of a matter that never has been litigated, because of a determination that it should have been advanced in an earlier suit.”
How later courts described this case
- explaining that the doctrine of res judicata "is often analyzed ... to consist of two preclusion concepts: 'issue preclusion’ and ‘claim preclusion’ ”: "Issue preclusion refers to the effect of a judgment in foreclosing relitigation of a matter that has been litigated and decided. .... Claim preclusion refers to the effect of a judgment in foreclosing litigation of a matter that never has been litigated, because of a determination that it should have been advanced in an earlier suit.”
- holding that “a federal court must give to a state-court judgment the same preclusive effect as would be given that judgment under the law of the State in which the judgment was rendered” pursuant to both the United States Constitution and the Full Faith and Credit Act, 28 U.S.C. § 1738
- finding certain constitutional claims not raised in prior state action barred by res judicata, and holding that 42 U.S.C. § 1983 does not guarantee a litigant the right to proceed to court on state claims in state court and then turn to federal court to adjudicate federal claims
- explaining that “federal courts may look to common law or to the policies supporting res judicata . . . in assessing the preclusive effect of decisions of other federal courts,” but must determine the preclusive effect of a state court judgment based on the law of that state
Written by the judges who cited it.
Distinguished
Distinguished by Trepel v. Pontiac Osteopathic Hospital, 599 F. Supp. 1484 (1984)
— U.S. -, 104 S.Ct. 892, 79 L.Ed.2d 56 (1984) is inapposite.
The opinion
*88 Justice White,
with whom The Chief Justice and Justice Powell join, concurring.
In Union & Planters’ Bank v. Memphis, 189 U. S. 71, 75 (1903), this Court held that a federal court “can accord [a state judgment] no greater efficacy” than would the judgment-rendering State. That holding has been adhered to on at least three occasions since that time. Oklahoma Packing Co. v. Oklahoma Gas & Electric Co., 309 U. S. 4, 7-8 (1940); Wright v. Georgia Railroad & Banking Co., 216 U. S. 420, 429 (1910); City of Covington v. First National Bank, 198 U. S. 100, 107-109 (1905). The Court has also indicated that the States are bound by a similar rule under the Full Faith and Credit Clause. Public Works v. Columbia College, 17 Wall. 521, 529 (1873). The Court is thus justified in this case to rule that preclusion must be determined under state law, even if there would be preclusion under federal standards..
This construction of 28 U. S. C. § 1738 and its predecessors is unfortunate. In terms of the purpose of that section, which is to require federal courts to give effect to state-court judgments, there is no reason to hold that a federal court may not give preclusive effect to a state judgment simply because the judgment would not bar relitigation in the state courts. If the federal courts have developed rules of res judicata and collateral estoppel that prevent relitigation in circumstances that would not be preclusive in state courts, the federal courts should be free to apply them, the parties then being free to relitigate in the state courts. The contrary construction of § 1738 is nevertheless one of long standing, and Congress has not seen fit to disturb it, however justified such an action might have been.
Accordingly, I join the opinion of the Court.