The Oyez Project: Judicial Power Issues - Collateral Estoppel Decisions

Federated Department Stores, Inc. v. Moitie

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Ford v. Ford

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Lance v. Dennis

Does the Rooker-Feldman doctrine preclude plaintiffs from bringing suit in federal court when they are in privity with a party that lost in state court?

No. In an anonymous 8-1 decision, the Court reversed the District Court. The Court held that "The Rooker-Feldman doctrine does not bar actions by nonparties to the earlier state-court judgment simply because [...] they could be considered in privity with a party to the judgment." Since Lance was not a party to the state-court suit, and was in no position to appeal the Colorado Supreme Court's decision, the District Court had jurisdiction to hear the case. Justice John Paul Stevens wrote a lone dissent expressing a desire to address the validity of the claims brought by Lance's suit.

Semtek v. Lockheed Martin

Is the claim-preclusive effect of a federal judgment dismissing a diversity action on statute-of-limitations grounds determined by the law of the state in which the federal court sits?

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that "[b]ecause the claim-preclusive effect of a federal court's dismissal 'upon the merits' of a diversity action on state statute-of-limitations grounds is governed by a federal rule, which in turn (in diversity cases) incorporates the claim-preclusion law that would be applied by state courts in the State in which the federal court sits, the Maryland Court of Special Appeals erred in holding that the California federal court's dismissal 'upon the merits' necessarily precluded the Maryland state-court action." Thus, the District Court's dismissal on the merits of claims as untimely under California law did not preclude Semtek from asserting its claims in a different state court forum.

United States v. Mendoza

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United States v. Stauffer Chemical Co.

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