Friday, December 6, 2013

Marrese v. American Academy of Orthopaedic Surgeons case brief

Marrese v. American Academy of Orthopaedic Surgeons case brief summary
470 U.S. 373 (1985)


CASE SYNOPSIS
Petitioners sought review of an en banc decision of the United States Court of Appeals for the Seventh Circuit, which held that claim preclusion barred petitioners' federal antitrust suit and reversed a contempt order because a discovery order was invalid.

PROCEDURAL HISTORY
The lower court held that claim preclusion barred petitioners' federal antitrust suit.

DISCUSSION

  • On certiorari, the U.S. Supreme Court held that the lower court erred by suggesting that, under the circumstances of the case, the federal court should determine the preclusive effect of a state court judgment without regard to the law of the state in which the judgment was rendered. 
  • The preclusive effect of a state court judgment in a subsequent federal lawsuit was determined by the full faith and credit statute, 28 U.S.C.S. § 1738, which provided that state judicial proceedings should have the same full faith and credit in every court within the United States as they had by law or usage in courts of the state from which they were taken. 
  • Section 1738 commanded a federal court to accept the rules chosen by the state from which the judgment was taken. 
  • The Court concluded that the basic approach adopted in Kremer applied in a lawsuit involving a claim within the exclusive jurisdiction of the federal courts.

CONCLUSION
The judgment was reversed and the case was remanded for further proceedings consistent with the opinion.


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