Friday, November 1, 2013

United States v. Mendoza case brief

United States v. Mendoza case brief summary
464 U.S. 154 (1984)

The Court granted certiorari to review a judgment of the United States Court of Appeals for the Ninth Circuit, which affirmed a judgment that precluded petitioner United States from litigating an issue against respondent alien that had previously been decided against the government in prior litigation not involving the alien.

Respondent alien filed a petition for naturalization, basing his claim in part on a prior decision not involving respondent that adjudicated an issue of due process common to both cases against petitioner United States.

  • Holding that the doctrine of nonmutual offensive collateral estoppel did not bind petitioner to the prior result, the Court reversed the judgment. 
  • The Court held that a non-party to a prior judgment could not assert collateral estoppel against the government, because the conduct of government litigation was sufficiently different from the conduct of private civil litigation so that the economy interests underlying a broad application of collateral estoppel were outweighed by the constraints which peculiarly affect the government. 
  • The Court noted that an the application of nonmutual offensive collateral estoppel would thwart development of important questions of law by freezing the first final decision rendered on a particular legal issue, would frustrate judicial interests, including the Court's own policy of awaiting conflicts among the circuit courts before granting certiorari, and would impair the government's discretion in deciding which cases to appeal.


The Court reversed the judgment for respondent alien, because respondent was not a party to a prior lawsuit against petitioner United States that decided a question of due process common to both cases against petitioner; the doctrine of nonmutual offensive collateral estoppel did not apply against petitioner, so respondent could not assert the prior judgment.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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