Primary Holding
After a judgment in a proceeding where both parties appeared and the issues were fully and fairly litigated, the matter giving rise to the judgment cannot be litigated again in a different state under the Full Faith and Credit Clause.
Facts
Durfee sought to quiet title to land on the Missouri River at the border between Missouri and Nebraska. The action was brought in Nebraska court, but it would have jurisdiction only if the land was found to be in Nebraska. The issues were litigated in that court, and Duke appeared there. The court established that it had jurisdiction and reached a final judgment in favor of Durfee, which was upheld in the state appellate courts. Duke later brought an action to quiet title on the same land in a Missouri court, which was transferred to federal court based on diversity of citizenship.
It turned out that the land was actually in Missouri, but the lower court still ruled that res judicata prevented it from hearing the case, since the Nebraska court had reached a final judgment on all of the issues, including jurisdiction. Duke successfully persuaded the appellate court that the Nebraska judgment should not be considered conclusive on the merits because that state did not have jurisdiction over land in Missouri. The appellate court thus ruled that it did not need to give full faith and credit to the earlier judgment or apply the principle of res judicata.
Opinions
Majority
- Potter Stewart (Author)
- Earl Warren
- William Orville Douglas
- Tom C. Clark
- John Marshall Harlan II
- William Joseph Brennan, Jr.
- Byron Raymond White
- Arthur Joseph Goldberg
The judgment in Nebraska would have full res judicata effect in Nebraska courts, so the only issue remaining for the Missouri court to address was whether the issues had been fully and fairly litigated as well as finally decided on the merits. Significant concerns about judicial finality require that there is only one trial on the issue, and they extend to questions of subject matter jurisdiction as well as more substantive issues. Parties that have thoroughly contested an issue should be bound by its result rather than allowed to seek a more favorable outcome. Disputes over real estate are subject to this rule as much as those regarding personal property. Some exceptions may apply in the context of federal preemption or sovereign immunity, but those concerns do not arise in this case.
Concurrence
- Hugo Lafayette Black (Author)
The decision of the Nebraska court would be binding in the event of an authoritative determination in an original suit between the two states or by an agreement between them.
Case Commentary
Since lack of subject matter jurisdiction is a defense that never is waived, it generally supersedes principles such as res judicata. But this is true only when the party asserting the defense did not appear in the original action, at which point the defense could have been raised and litigated. The original court's findings on subject matter jurisdiction will not be disturbed otherwise, even if they appear to be incorrect.
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