Dufree v. Duke

Brief Fact Summary.

Petitioner brought suit in Nebraska over quiet title of land. Subsequently, Respondent brought suit in Missouri over quiet title of the same land.

Synopsis of Rule of Law.

Under the Full Faith and Credit Clause, a state may not relitigate a foreign judgment that has been fully and fairly litigated.

Facts.

First, Dufree (Petitioner) sued Duke (Respondent) for quiet title of land on the Missouri River, bringing the suit in Nebraska. Nebraska’s subject matter jurisdiction over the case depended on whether the land was in Nebraska or Missouri. Following this lawsuit, Respondent sued Petitioner for quiet title of the same land, bringing suit in Missouri under the argument that Nebraska lacked subject matter jurisdiction.

Issue.

Was Respondent precluded, under res judicata, from litigating the claims regarding subject matter jurisdiction and quiet title in Missouri?

Held.

Yes, the Respondent’s claims were barred by res judicata. Reversed.

Concurrence.

Justice Black

Justice Black concurred in the reversal of the judgment but clarified that the Respondent would not be bound to the Nebraska judgment if it was later determined that the land was located in Missouri and not Nebraska.

Discussion.

The Court determined that because the specific claims regarding subject matter jurisdiction and quiet title were fully and fairly litigated in Nebraska, Missouri was precluded under res judicata from retrying the issues.