DEFENSE · 42usc1983:x-collateral-estoppel
Under Allen v. McCurry (449 U.S. 90 (1980)) and 28 U.S.C. § 1738, federal courts hearing § 1983 actions give state-court judgments the same preclusive effect they would have in the courts of that State, provided there was a full and fair opportunity to litigate the identical issue.
Exact element source
in an action at law, suit in equity, or other proper proceeding for redressSource:
docroot/ir/usc/title42.jsonl#title42_sec1983; Unicode character offsets [441:516] (end exclusive); SHA-256 88fe01322b9d94860a669ec452f558146e2745845070bc43583671ce12acb2bb.Routes and case patterns
| Route | Definition | Merits instance blocks | Distinct merits cases | Examples (up to 3 cases per count group) |
|---|---|---|---|---|
| _whole accepted; provisional (1 case) | The element is decided as a whole: the reasoning turns on no narrower doctrinal sub-question that distinguishes it from any other application of this element. | 0 Satisfied 0; not satisfied 0; excluded context 1 | 0 | Used only in non-merits blocks (1). Excluded context examples:Dye v. City of Warren — 367 F. Supp. 2d 1175 (2005) · United States District Court for the Northern District of Ohio · 2005 — not · law (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed) · applied/procedural · not counted |
How courts decided this element
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Dye v. City of Warren — 367 F. Supp. 2d 1175 (2005) · United States District Court for the Northern District of Ohio · 2005 — not · law (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed) | Issue preclusion / collateral estoppel from prior state criminal or civil judgment (Allen v. McCurry) | not Excluded from merits counts applied / procedural basis: law Not preclusive, yet the same plea and stipulations are then used as admissions to defeat the claim on the merits. | issue-preclusion/no-contest-plea-does-not-bar-excessive-force-claim | Mr. Dye, represented through his attorney James Tekavec, withdrew his prior not guilty pleas and entered a plea of no contest with consent to a finding of guilty on the disorderly conduct charge.Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [10041:10236] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.During the pretrial hearing Mr. Dye also stipulated to probable cause for the charges of resisting arrest and reckless operation of a vehicle.Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [10373:10515] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.The Supreme Court has held that issues decided in a state court criminal proceeding may have a collateral estoppel effect in a section 1983 civil rights action, but only to the extent that the plaintiff sought relitigation of the same issues which were previously decided in the criminal proceeding.Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [19925:20224] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.Consequently, in this case, the issue of whether Chief Mandopoulos used excessive force in arresting Mr. Dye was neither actually litigated nor necessary to a determination on the charge of disorderly conduct in state court.Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [22826:23050] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f. |
Court interpretations
interpretation
The Supreme Court has held that issues decided in a state court criminal proceeding may have a collateral estoppel effect in a section 1983 civil rights action, but only to the extent that the plaintiff sought relitigation of the same issues which were previously decided in the criminal proceeding.
Dye v. City of Warren — 367 F. Supp. 2d 1175 (2005) · United States District Court for the Northern District of Ohio · 2005 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)
The Supreme Court has held that issues decided in a state court criminal proceeding may have a collateral estoppel effect in a section 1983 civil rights action, but only to the extent that the plaintiff sought relitigation of the same issues which were previously decided in the criminal proceeding.Source:
docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [19925:20224] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.Under Allen v. McCurry (449 U.S. 90 (1980)) and 28 U.S.C. § 1738, federal courts hearing § 1983 actions give state-court judgments the same preclusive effect they would have in the courts of that State, provided there was a full and fair opportunity to litigate the identical issue.