United States v. Mendoza, 464 U.S. 154 (1984)
Constitutional issues are not precluded from further litigation based on the application of non-mutual offensive collateral estoppel against the federal government.
Mendoza, a citizen of the Philippines, filed a petition for naturalization in the U.S. under a statute that already had expired according to its own provisions. He argued that his due process rights had been infringed by the government's administration of the Nationality Act. However, the lower courts did not address the merits of his claim, ruling instead that the government could not litigate the issue of due process under collateral estoppel principles. This was because it had lost an earlier case brought by Filipino citizens in a federal district court.Opinions
- William Hubbs Rehnquist (Author)
- Warren Earl Burger
- William Joseph Brennan, Jr.
- Byron Raymond White
- Thurgood Marshall
- Harry Andrew Blackmun
- Lewis Franklin Powell, Jr.
- John Paul Stevens
- Sandra Day O'Connor
Collateral estoppel should apply less broadly in the context of government litigation than in the context of private civil litigation, since there are some critical differences between them. The lower courts used a standard requiring the government to show evidence in the record that there was a crucial need to reconsider the due process question in order to effectively administer immigration laws. This standard is too demanding and too subjective to be consistently applied by the courts or followed by the government. Legal doctrine in the area of immigration should be encouraged to develop as circumstances change, rather than being frozen by collateral estoppel.Case Commentary
This decision was based on policy arguments more than conventional legal reasoning, and it stands for the proposition that the government can try to convince courts that other courts wrongly resolved the issue. Questions of fairness arise when the government gets superior treatment to a private party.
U.S. Supreme CourtUnited States v. Mendoza, 464 U.S. 154 (1984)
United States v. Mendoza
Argued November 2, 1983
Decided January 10, 1984
464 U.S. 154
Respondent, a Filipino national, filed a petition for naturalization under the Nationality Act of 1940, as amended, asserting that he had been denied due process of law by the Government's administration of the Act with regard to the naturalization in the Philippines in 1945 and 1946 of noncitizens who had served in the Armed Forces of the United States during World War II. The naturalization examiner recommended denial of the petition, but the Federal District Court granted the petition without reaching the merits of respondent's constitutional claim. The court held that the Government was collaterally estopped from litigating the constitutional issue because of an earlier, unappealed Federal District Court decision against the Government in a case brought by other Filipino nationals. The Court of Appeals affirmed.
Held: The United States may not be collaterally estopped on an issue such as the one involved here, adjudicated against it in an earlier lawsuit brought by a different party. Pp. 464 U. S. 158-164.
(a) Under the doctrine of collateral estoppel, once a court has decided an issue of fact or law necessary to its judgment, that decision is conclusive in a subsequent suit based on a different cause of action involving a party to the prior litigation. However, the doctrine of nonmutual offensive collateral estoppel, under which a nonparty to a prior lawsuit may make "offensive" use of collateral estoppel against a party to the prior suit, is limited to private litigants, and does not apply against the Government. Pp. 464 U. S. 158-159.
(b) The Government is not in a position identical to that of a private litigant, both because of the geographic breadth of Government litigation and also, most importantly, because of the nature of the issues the Government litigates, frequently involving legal questions of substantial public importance. A rule allowing nonmutual collateral estoppel against the Government would substantially thwart the development of important questions of law by freezing the first final decision rendered on a particular legal issue, and would require substantial revision of the Solicitor General's policy for determining when to appeal an adverse decision, a policy that involves consideration of a variety of factors, such as the Government's limited resources and the crowded court dockets. Pp. 464 U. S. 159-162.
(c) The conduct of Government litigation in the federal courts is sufficiently different from the conduct of private civil litigation in those courts so that what might otherwise be economy interests underlying a broad application of nonmutual collateral estoppel are outweighed by the constraints which peculiarly affect the Government. Pp. 464 U. S. 162-163.
672 F.2d 1320, reversed.
REHNQUIST, J., delivered the opinion for a unanimous Court.