Migra v. Warren City Sch. Dist. Bd. of Educ. - 465 U.S. 75, 104 S. Ct. 892 (1984)

Rule:

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.

Facts:

Petitioner, Dr. Ethel D. Migra, was employed by respondent Warren, Ohio, Board of Education (Board) as a supervisor of elementary education on an annual basis under written contracts. The Board, at a regularly scheduled meeting, adopted a resolution renewing Migra’s employment for the 1979-1980 school year, and, upon being advised of this, petitioner accepted the appointment by letter. But shortly thereafter, the Board, at a special meeting at which four of its five members were present, voted 3 to 1 not to renew Migra’s employment, and so notified her in writing. Migra then brought suit in the Ohio Court of Common Pleas against the Board and the three members who had voted not to renew her employment. The complaint alleged two causes of action -- a breach of contract by the Board and wrongful interference by the individual members with petitioner's employment contract. The trial court held that Migra’s acceptance of the employment proffered for 1979-1980 created a binding contract and that the Board's subsequent action purporting not to renew the employment had no legal effect, and awarded Migra reinstatement and compensatory damages. The court granted Migra’s motion to dismiss without prejudice "the issue of conspiracy and individual board member liability," which issue the court had previously "reserved and continued." The Ohio Court of Appeals affirmed, and review was denied by the Ohio Supreme Court. Thereafter, Migra filed an action in Federal District Court under 42 U. S. C. § 1983 (1976 ed., Supp. V), inter alia, against the Board, its members, and the Superintendent of Schools, alleging that because of her activities involving a desegregation plan for the Warren elementary schools and a social studies curriculum that she had prepared, the Board members determined not to renew her contract, and that the Board's actions violated her rights under the First,  Fifth, and Fourteenth Amendments. She requested injunctive relief and compensatory and punitive damages. The District Court granted summary judgment for the defendants on the basis of res judicata, inter alia, and dismissed the complaint. The United States Court of Appeals affirmed.

Issue:

Do state-court judgments have the same claim preclusive effect in 42 USCS 1983 federal court suit as in state courts?

Answer:

Yes

Conclusion:

The court held that Migra’s claims under 42 U.S.C.S. §§ 1983 and 1985 were subject, without qualification, to the preclusive effect of the prior judgment, pursuant to the full faith and credit statute, 28 U.S.C.S. § 1738. But the court vacated the judgment and remanded for a determination whether Migra’s claims were in fact precluded under state law. The court held that §§ 1983 and 1985 contained no modification, express or implied, of the U.S. Const. art. IV, § 1, doctrine of full faith and credit, as implemented by § 1738. The court made it clear that § 1738, and preclusion, applied not only to issues actually litigated, but also to claims that were not, but could have been litigated in the prior proceeding, if the relevant state law had such effect. The court held that given Migra’s ability to enjoy federal question jurisdiction, her access to a federal court's "expertise" in federal law was unimpaired.