Supreme Court of the United States
Migra v. Warren City School District Board of Education
January 23, 1984465 U.S. 75
Summary
The Court held that a state-court judgment has the same claim-preclusive effect in a subsequent federal action under 42 U.S.C. § 1983 as it would have in the courts of the State that rendered the judgment. Because federal law did not modify the ordinary operation of 28 U.S.C. § 1738, Ohio preclusion law governs whether Dr. Migra's federal claims were barred, and the Court remanded for that determination. The Court did not itself decide whether Ohio law actually barred the federal action.
Holding
- Whether a state-court judgment may bar claims under 42 U.S.C. § 1983 that could have been raised in the state action. Section 1983 does not override 28 U.S.C. § 1738 or prevent a state-court judgment from receiving the same claim-preclusive effect in federal court that it would receive under the law of the rendering State.
Docket 82-738
Cited authorities
- Rule 13 of the Ohio Rules of Civil Procedure
- Rule 13 of the Federal Rules of Civil Procedure
- CA10
- 42 U.S.C. §§ 1983
- 42 U.S.C. §§ 1983
- 28 U.S.C. § 1738
- 42 U.S.C. § 1983
- 28 U.S.C. § 1738
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