Allen v. McCurry

449 U.S. 90 (1980)



Under res judicata, a final judgment on the merits of an action precludes the parties or their privies from relitigating issues that were or could have been raised in that action.


The plaintiff was convicted of drug possession and assault. On appeal, he did not allege that the state court denied him a full and fair opportunity to litigate his claims. Thus, he was barred by the decision in Stone v. Powell (unable to seek writ of habeas corpus). Later, the plaintiff brought a damages suit arising from the same incident. The district court granted summary judgment for the defendants in the second case under the doctrine of collateral estoppel.


Did the doctrine of collateral estoppel prevent the petitioner from seeking damages in the second case?


Yes, the Court held that collateral estoppel applies to the petitioner’s suit.


The Court recognized that every person asserting a federal right is entitled to one full opportunity to litigate in court. However, legislative history did not support giving parties another opportunity to relitigate in federal court if the state court, acting within proper jurisdiction, gave the parties a full and fair opportunity already. The Court also dismissed the argument that state courts are untrustworthy to decide constitutional issues.

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