Durfee v. Duke

Brief Fact Summary.

Plaintiff wins suit in Nebraska but Defendant brings suit in Missouri and wins. The question the court considers is whether Nebraska’s judgement is entitled to full faith and credit in Missouri state and federal court.

Synopsis of Rule of Law.

Under the Full Faith and Credit Clause a state court’s judgement on subject matter jurisdiction is entitled to res judicata in other states and federal courts if the question was fully and fairly litigated.

Facts.

Plaintiff Durfee sued Defendant Duke in Nebraska state court to quiet title on land between the Missouri River between Nebraska and Missouri. The Nebraska court’s subject matter jurisdiction depended on the land being in Nebraska. Defendant Duke contested jurisdiction but still litigated the case to the end. The Nebraska court found that the land was a part of Nebraska by avulsion, found jurisdiction proper, and ruled in favor of Plaintiff Durfee. Defendant Duke appealed and the Nebraska Supreme Court affirmed. Defendant Duke then sued in Missouri to quiet title claiming the land was in Missouri and that Nebraska did not have proper jurisdiction. The case was removed to federal court based on diversity of citizenship. The federal district court held that the land was in Missouri, but that res judicata applied and the judgement of the Nebraska Supreme Court controlled. The court of appeals reversed ruling that the Nebraska decision was not entitled to full faith and credit. The appellate court thus held that a Missouri court had the right to reconsider the Nebraska’s court’s subject matter jurisdiction. Plaintiff Durfee petitioned the Supreme Court of the United States for certiorari.

Issue.

Is a state’s ruling on subject matter jurisdiction entitled to full faith and credit in other state and federal courts?

Held.

Yes, a state’s ruling on subject matter jurisdiction is entitled to full faith and credit in other state and federal courts. The judgement of the appellate court is reversed and that of the district court is affirmed.

Discussion.

1. One state court’s judgement is entitled to full faith and credit which bars parties from bringing issues in other courts that have already been litigated and decided in another state.
2. This means a state court’s ruling on subject matter jurisdiction must be res judicata effect.
3. Precedent tells us that the Full Faith and Credit Clause requires a court’s decision to be given res judicata effect only if the court had jurisdiction.
4. Whether the previous court had jurisdiction depends on whether the question was fully and fairly litigated.
5. The Nebraska court’s decision is thus entitled to res judicata effect under the Full Faith and Credit Clause.
6. The judgement of the appellate court is reversed and that of the district court is affirmed.