Marrese v. American Academy of Orthopaedic Surgeons

470 U.S. 373, 105 S. Ct. 1327 (1985)

 

RULE:

The preclusive effect of a state court judgment in subsequent federal lawsuit generally is determined by full faith and credit statute, which provides that state judicial proceedings shall have same full faith and credit in every court within United States as they have by law or usage in courts of such state from which they are taken. 28 U.S.C.S. § 1738. This statute directs federal court to refer to preclusion law of state in which judgment was rendered. Section 1738 does not allow federal courts to employ their own rules of res judicata in determining effect of state judgments. Rather, it goes beyond common law and commands federal court to accept rules chosen by state from which judgment is taken. Section 1738 embodies concerns of comity and federalism that allow states to determine, subject to requirements of statute and Due Process Clause, preclusive effect of judgments in their own courts.

FACTS:

The lower court held that claim preclusion barred petitioners' federal antitrust suit. On certiorari, the U.S. Supreme Court held that the lower court erred by suggesting that, under the circumstances of the case, the federal court should determine the preclusive effect of a state court judgment without regard to the law of the state in which the judgment was rendered.

ISSUE:

May a state court judgment have preclusive effect on a federal antitrust claim that could not have been raised in the state proceeding?

ANSWER:

Yes.

CONCLUSION:

Although federal antitrust claims are within the exclusive jurisdiction of the federal courts, the Court of Appeals ruled that the dismissal of petitioners' complaints in state court barred them from bringing a claim based on the same facts under the Sherman Act. The Court of Appeals erred by suggesting that in these circumstances a federal court should determine the preclusive effect of a state court judgment without regard to the law of the State in which judgment was rendered. 

Moreover, the preclusive effect of a state court judgment in a subsequent federal lawsuit generally is determined by the full faith and credit statute, which provides that state judicial proceedings "shall have the same full faith and credit in every court within the United States . . . as they have by law or usage in the courts of such State . . . from which they are taken." This statute directs a federal court to refer to the preclusion law of the State in which judgment was rendered.

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