Federated Department Stores, Inc. v. Moitie

Brief Fact Summary.

Respondents separately sued Petitioner for treble damages, following a government lawsuit against Petitioner. Respondents cases were consolidated in federal court.

Synopsis of Rule of Law.

Res judicata precludes the same parties from relitigating issues that were or could have been raised in the previous action.

Facts.

Federated Department Stores, Inc. (Petitioner) was sued by the U.S. for violating antitrust laws. In addition to five other retail purchasers, Moitie (Respondent) filed a private action seeking treble damages against Petitioner in state court and Brown (Respondent) filed a private action seeking treble damages against Petitioner in federal court. Moitie’s case was removed to federal court and the cases were consolidated.

Issue.

Did the Ninth Circuit create a valid exception to res judicata?

Held.

No, the Ninth Circuit’s exception was not valid. The case is reversed and remanded.

Dissent.

Justice Brennan

Justice Brennan argued that the Court’s decision was unclear and would encourage litigants to split their lawsuits between state and federal court.

Concurrence.

Justice Blackmun

Justice Blackmun agreed with the Court’s decision, but would not close the door to exceptions to res judicata based on public policy concerns.

Discussion.

The Court rejected the Ninth Circuit’s exception to res judicata as contrary to precedent. The Court recognizes no general equitable doctrine to res judicata and the furtherance of justice and public policy would not be hindered by the application of res judicata.