Allen v. McCurry

Brief Fact Summary.

Man found guilty of drug possession in state court attempts to raise a Fourth Amendment claim in federal court when he already raised it in the state court proceeding.

Synopsis of Rule of Law.

Collateral estoppel is applicable to a federal suit if the issue was previously decided in state court.

Facts.

McCurry was arrested and tried in state court for possession of heroin. McCurry sought to suppress the evidence claiming the police uncovered it as a result of an illegal search under the Fourth Amendment. But the state court still admitted the evidence. McCurry then brought suit against Allen and others under § 1983 alleging they violated his Fourth Amendment rights. The district court granted Defendants’ motion for summary judgement on the basis that McCurry was estopped from because he already raised his Fourth Amendment issue in the state court proceeding. The Eighth Circuit Court of Appeals reversed and the defendants appealed.

Issue.

Does collateral estoppel apply to a federal suit if the issue was previously decided in state court?

Held.

Does collateral estoppel apply to a federal suit if the issue was previously decided in state court?

Dissent.

Justice Justice Blackmun with Justices Brennan and Marshall dissenting

Collateral estoppel should not apply because when § 1983 was passed mutuality applied, which requires collateral estoppel only be applied when the new proceeding contains the same parties as the previous proceeding. However, mutuality does not apply now which means Plaintiff McCurry’s claims are different. Also, a Fourth Amendment claim being raised to exclude evidence versus being brought under § 1983 is completely different. Would affirm the judgement of the court of appeals.

Discussion.

1. There is no evidence in § 1983 that Congress intended to allow plaintiffs to relitigate an issue already decided just because the judgement occurred on the state level.
2. State courts have just as much ability to protect federal rights as federal courts do.
3. Collateral estoppel applies to Plaintiff McCurry’s federal Fourth Amendment claim because he already raised it in his state proceeding and he is therefore barred from relitigating it.
4. Judgement of the appeals court is reversed and the case is remanded.