United States v. Stauffer Chem. Co.
Annotate this Case
464 U.S. 165 (1984)
U.S. Supreme Court
United States v. Stauffer Chem. Co., 464 U.S. 165 (1984)
United States v. Stauffer Chemical Co.
Argued November 2, 1983
Decided January 10, 1984
464 U.S. 165
When officials of the Environmental Protection Agency (EPA) and the State of Tennessee, accompanied by employees of a private firm under contract to EPA, attempted to inspect one of respondent's Tennessee plants, respondent refused entry to the private contractors unless they would sign an agreement not to disclose trade secrets. The private contractors refused to do so, and EPA later obtained an administrative warrant authorizing the private employees to conduct the inspection. After respondent refused to honor the warrant, the Government began a civil contempt proceeding against respondent in Federal District Court in Tennessee, and respondent moved to quash the warrant on the ground that private contractors are not "authorized representatives" under § 114(a)(2) of the Clean Air Act for the purposes of conducting inspections of premises subject to regulation under the Act. The court denied respondent's motion, and on appeal respondent reiterated its statutory argument and also asserted that the Government should be collaterally estopped from asserting that § 114(a)(2) authorizes private contractors to conduct inspections, because of a contrary decision of the Court of Appeals for the Tenth Circuit in a case involving the same parties which arose from respondent's similar refusal to allow private contractors, accompanying EPA and Wyoming officials, to enter and inspect one of respondent's Wyoming plants. The Court of Appeals in the present case reversed the District Court, agreeing with respondent both on the merits of the statutory issue and, alternatively, on the collateral estoppel issue.
Held: The doctrine of mutual defensive collateral estoppel is applicable against the Government to preclude relitigation of the same issue already litigated against the same party in another case involving virtually identical facts. Cf. Montana v. United States, 440 U. S. 147. Pp. 464 U. S. 169-174.
(a) The doctrine of collateral estoppel generally applies to preclude relitigation of both issues of law and issues of fact if those issues were conclusively determined in a prior action involving the same parties. The exception to the applicability of the principles of collateral estoppel for "unmixed questions of law" arising in "successive actions involving unrelated subject matter," Montana v. United States, supra, at 440 U. S. 162, does not apply here. Whatever the purpose or extent of the exception,
there is no reason to apply it here to allow the Government to litigate twice with the same party an issue arising in both cases from virtually identical facts. Pp. 464 U. S. 169-172.
(b) Nor is an exception to the doctrine of mutual defensive estoppel justified here on the asserted ground that its application in Government litigation involving recurring issues of public importance will freeze the development of the law. That argument is persuasive only to prevent the application of collateral estoppel against the Government in the absence of mutuality. While the Sixth Circuit's decision prevents EPA from relitigating the § 114(a)(2) issue with respondent, it still leaves EPA free to litigate the same issue in the future with other litigants. Pp. 464 U. S. 173-174.
684 F.2d 1174, affirmed.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, MARSHALL, BLACKMUN, POWELL, STEVENS, and O'CONNOR, JJ., joined. WHITE, J., filed an opinion concurring in the result, post, p. 464 U. S. 174.
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