Federated Dep't Stores v. Moitie

452 U.S. 394, 101 S. Ct. 2424 (1981)



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.


Respondents were two of several private litigants who had brought federal actions against petitioner department store seeking treble damages as a proposed class of retail purchasers following an antitrust action against petitioner.


Is the modification allowed by res judicata?




Petitioner removed the case to federal court and moved to dismiss on the ground of res judicata. The district court granted the motion to dismiss, but the court of appeals reversed the dismissal when the actions of the other private litigants were reinstated on appeal. The court of appeals found that although respondents' actions were technically barred by res judicata, basic principles of public policy and simple justice required an exception to that doctrine. Petitioner appealed and the court reversed the decision and remanded the cause for further proceedings, finding that the dismissal of respondents' original actions was final when they failed to appeal and, under such circumstances, there was no equitable doctrine that provided an exception to the principle of res judicata.

Click here to view the full text case and earn your Daily Research Points.