FACTS: Defendant was convicted in state court after his motion to suppress evidence on federal constitutional grounds was denied. Because defendant did not assert that the state court had denied him a fair opportunity to litigate his constitutional claims, he was barred from seeking a writ of habeas corpus in federal court. Defendant nonetheless sought relief in federal court by bringing suit under 42 U.S.C.S. § 1983 against the officers who entered his home and seized the evidence used to convict him.
On appeal, the Court held that defendant's suit was his only means of constitutional redress, and that the officers could not assert collateral estoppel as a defense.
The Court concluded that nothing in the language or legislative history of 42 U.S.C.S. § 1983 proved a congressional intent to deny binding effect to a state court judgment, when that court had given the parties a full and fair opportunity to litigate their federal claims. The Court noted that 42 U.S.C.S. § 1983 afforded an opportunity for federal relief for certain types of injuries, and was not intended as a substitute for a federal writ of habeas corpus.
CONCLUSION: The Court reversed the lower appellate court's judgment.
Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?