Durfee v. Duke

375 U.S. 106 (1963)

What's Going On?

The Supreme Court granted certiorari to review a federal appellate court's decision holding that res judicata principles did not apply to a judgment rendered in another state, in an action involving a dispute to title over land.

Who's Who?

Petitioners   :

[Gene and Laura] Durfee – (original plaintiffs) husband and wife claiming title to land located on the Missouri River.

Respondent :

Duke – (original defendant) woman claiming title to land located on the Missouri River.

Facts:

Petitioners [Gene and Laura] Durfee brought an action against Respondent Duke in a Nebraska state court to quiet title to land located on the Missouri River, the main channel of which forms the boundary between Nebraska and Missouri. Jurisdiction would only be proper in the Nebraska court if the land in question was in Nebraska. The single question of whether a shift in the river's course had been caused by avulsion or accretion determined whether the land was considered Nebraska land. Respondent litigated the issues in the Nebraska court, and contested the court's jurisdiction. Both the Nebraska trial and supreme courts found for Petitioners , holding that the shift was caused by avulsion, that the land was in Nebraska, and that title to the land be quieted in Petitioners. Respondent then brought suit against Petitioners in Missouri to quiet title to the same land, claiming that the land was in Missouri. The suit was removed to a federal district court on grounds of diversity. The district court was of the opinion that the land was in Missouri, but held that the judgment of the Nebraska Supreme Court was res judicata and binding upon the court. The appellate court reversed, holding that principles of res judicata did not apply and that the Nebraska judgment was not owed full faith and credit because the controversy involved land and a court in Missouri. The Supreme Court granted certiorari.

Issue:

May courts be required to give full faith and credit to judgments rendered in other courts on the issue of jurisdiction?

Decision:

Yes. The Constitutional provision for full faith and credit, as applied to the doctrine of res judicata, generally requires every state to give a judgment the res judicata effect which the judgment would be accorded in the state that rendered it. Respondent argues that, whatever the effect of the Nebraska judgment in favor of Petitioners, the federal district court in Missouri was free to determine whether the land in question was actually in Nebraska, in order to ascertain whether the Nebraska court had jurisdiction over the subject matter. This court has held many times that a judgment of a court is conclusive upon the merits of another state only if the court in the original judgment had proper jurisdiction. There are limits, however, to the rule that a court in one state may constitutionally inquire into a foreign court's jurisdiction to render that judgment. Where the question of subject-matter jurisdiction has been fully litigated in the original forum, the issue cannot be retried in a subsequent action between the parties. The principles of res judicata apply to questions of jurisdiction. This case presents no exceptions to the rule of finality of jurisdictional determinations, such as federal pre-emption or sovereign immunity. The jurisdictional issues had been fully and fairly litigated in the Nebraska courts, and the district court in Missouri was correct in ruling that further inquiry was precluded. Affirmed.

Basic Rule:

A judgment is entitled to full faith and credit—even as to questions of jurisdiction—when the second court's inquiry disclosed that those questions have been fully and fairly litigated and finally decided in the court which rendered the original judgment.

Concurrence:

Neither Nebraska nor Missouri has the power to make determinations binding on the other state as to which state the land is in. The majority is correct in concluding that the judgment of the Nebraska court is binding for the purposes of resolving the dispute between the litigants in this case; however, the Court is not deciding the question of whether Respondent would continue to be bound by the Nebraska judgment should it later be decided between Missouri and Nebraska that the disputed tract is in Missouri.

Terms:

Accretion :

The increase of land by gradual accumulation due to natural forces.

Avulsion :

A sudden removal of land by currents, the change in course of a body of water, or flood.

Res judicata :

Latin for “the thing has been decided.” 1. Doctrine under which a final judgment by a court of competent jurisdiction preclusive relitigation by the parties of the same issue or cause of action in a subsequent case. 2. An issue that has been decided by a court of competent jurisdiction and carries a preclusive effect.

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