Marrese v. American Academy of Orthopedic Surgeons

Brief Fact Summary.

Petitioners separately sued Respondent in state court after they were denied membership.

Synopsis of Rule of Law.

The Full Faith and Credit Clause requires a federal court look to the state’s law regarding res judicata in order to determine if a matter litigated in that state may be relitigated in federal court.

Facts.

Dr. Marrese and Dr. Treister (Petitioners), orthopedic surgeons, were denied membership in the American Academy of Orthopaedic Surgeons (Respondent) without a hearing or statement of reason. The Petitioners separately brought suit in Illinois state court, without alleging any violation of state law.

Issue.

May a federal antitrust claim be barred under res judicata by a state court judgment?

Held.

Yes, the claim may be barred. The case is remanded to determine the state law of res judicata.

Concurrence.

Justice Burger

Justice Berger agreed with the Court’s decision, but noted that the Court should have created a federal rule addressing cases where state law does not speak to res judicata.

Discussion.

The Court determined that the Appeals Court erred by not considering the state law of res judicata, consistent with the requirements of the Full Faith and Credit Clause, and thus improperly created a rule that gave state court judgments greater preclusive effect than the state courts allowed. Furthermore, the Court declined to create an exception regarding the rule under the Full Faith and Credit Clause because the facts of this case before the Court did not require it.