Both the Constitution and a contemporane- ously enacted statute require federal courts to give “full faith and credit” to state court judgments, to give, that is, preclusive effect to state court judgments when those judgments would be given preclusive effect by the courts of that state.1356 The present Court views the interpretation of “full faith and credit” in the overall context of deference to state courts running throughout this section. “Thus, res judicata and collateral estoppel not only reduce unnecessary litigation and foster reliance on adjudication, but also promote the comity between state and federal courts that has been recognized as a bulwark of the federal system.”1357 42 U.S.C. § 1983 is not an exception to the mandate of the res judicata statute.1358 An exception to § 1738 “will not be recognized unless a later statute contains an express or implied partial repeal.”1359 Thus, a claimant who pursued his employment discrimination remedies through state administrative procedures, as the federal law requires her to do (within limits), and then appealed an adverse state agency decision to state court will be precluded from bringing her federal claim to federal court, since the federal court is obligated to give the state court decision “full faith and credit.”1360
Closely related is the Rooker-Feldman doctrine, holding that federal subject-matter jurisdiction of federal district courts does not extend to review of state court judgments.1361 The Supreme Court, not federal district courts, has such appellate jurisdiction. The doctrine thus prevents losers in state court from obtaining district court review, but “does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions.”1362
- Article IV, § 1, of the Constitution; 28 U.S.C. § 1738.
- Allen v. McCurry, 449 U.S. 90, 95–96 (1980).
- 449 U.S. at 96–105. In England v. Louisiana Bd. of Medical Examiners, 375 U.S. 411 (1964), the Court held that, when parties are compelled to go to state court under Pullman abstention, either party may reserve the federal issue and thus be enabled to return to federal court without being barred by res judicata.
- Kramer v. Chemical Construction Corp., 456 U.S. 461, 468 (1982).
- 456 U.S. 468–76. There were four dissents. Id. at 486 (Justices Blackmun, Brennan, and Marshall), 508 (Stevens).
- The doctrine derives its name from Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983).
- Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005) (Rooker-Feldman has no application when federal court proceedings have been initiated prior to state court proceedings; preclusion law governs in that situation).