Sunday, November 24, 2013

Federated Department Stores v. Moitie case brief

Federated Department Stores v. Moitie case brief summary
452 U.S. 394 (1981)

Petitioner department store sought certiorari review of a decision from the United States Court of Appeals for the Ninth Circuit, which reversed an order that dismissed the actions of respondent retail purchasers on the ground of res judicata by concluding that respondents were entitled to an exception from the application of the doctrine of res judicata based upon principles of public policy and simple justice.

Respondents were two of several private litigants who had brought federal actions against petitioner department store seeking treble damages as a proposed class of retail purchasers following an antitrust action against petitioner. All of the private actions were dismissed by the district court and all but respondents challenged the dismissals. Respondents brought a state action against petitioner. Petitioner removed the case to federal court and moved to dismiss on the ground of res judicata. The district court granted the motion to dismiss, but the court of appeals reversed the dismissal when the actions of the other private litigants were reinstated on appeal. The court of appeals found that although respondents' actions were technically barred by res judicata, basic principles of public policy and simple justice required an exception to that doctrine.

Petitioner appealed and the court reversed the decision and remanded the cause for further proceedings, finding that the dismissal of respondents' original actions was final when they failed to appeal and, under such circumstances, there was no equitable doctrine that provided an exception to the principle of res judicata.

The court reversed the judgment in favor of respondents and remanded the cause for further proceedings.

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