Durfee v. Duke
375 U.S. 106 (1963)
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Rule of Law:
Under the Full Faith and Credit Clause, a judgment is entitled to res judicata effect, even as to the court's subject-matter jurisdiction, when the jurisdictional issue was fully and fairly litigated and finally decided in the original proceeding.
Facts:
- Durfee and Keiffer disputed the ownership of a tract of bottom land located on the Missouri River.
- The Missouri River serves as the border between the states of Nebraska and Missouri.
- The state in which the land was situated depended on a factual question: whether a historical shift in the river's course was caused by avulsion or accretion.
- Durfee initiated a lawsuit against Keiffer in a Nebraska court to quiet title to the land.
- In the Nebraska proceeding, Keiffer appeared and through her counsel, fully litigated the issue, specifically contesting the court's subject-matter jurisdiction by arguing the land was in Missouri.
Procedural Posture:
- Durfee brought an action against Keiffer in a Nebraska state trial court to quiet title.
- The Nebraska trial court found in favor of Durfee.
- Keiffer, as appellant, appealed to the Supreme Court of Nebraska.
- The Supreme Court of Nebraska, as the state's highest court, affirmed the trial court's judgment.
- Keiffer then filed a new suit against Durfee in a Missouri state court to quiet title to the same land.
- The case was removed to the U.S. District Court for the Western District of Missouri on the basis of diversity jurisdiction.
- The District Court held the Nebraska judgment was res judicata and ruled in favor of Durfee.
- Keiffer, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals reversed the District Court, holding that the Nebraska judgment was not entitled to full faith and credit on the jurisdictional issue.
- The U.S. Supreme Court granted certiorari to review the judgment of the Court of Appeals.
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Issue:
Does the Full Faith and Credit Clause require a court in one state to give res judicata effect to another state court's judgment regarding title to land, when the first court's subject-matter jurisdiction was dependent on the land's location and that jurisdictional fact was fully and fairly litigated by the parties?
Opinions:
Majority - Justice Stewart
Yes. A judgment is entitled to full faith and credit, even as to questions of jurisdiction, when the second court's inquiry discloses that those questions have been fully and fairly litigated and finally decided in the court which rendered the original judgment. The principles of res judicata apply to questions of subject-matter jurisdiction just as they do to other issues. While courts of one state generally lack jurisdiction to affect title to land in another, the location of the land itself is a factual matter to be resolved by judicial determination. Once a party has their day in court and a full opportunity to present evidence on the jurisdictional issue, a collateral attack merely retries the issue, and there is no reason to expect a more satisfactory result. Therefore, because Keiffer fully and fairly litigated the jurisdictional question in Nebraska, the Nebraska court's determination that it had jurisdiction is binding, and the Missouri court must give that judgment full faith and credit.
Concurring - Justice Black
Yes. Justice Black concurred in the judgment with the understanding that the decision only binds the private parties in this specific dispute. He clarified that the Court was not deciding whether Keiffer would remain bound by the Nebraska judgment if the states of Missouri and Nebraska were to later authoritatively resolve their boundary dispute, either through an original proceeding in the Supreme Court or by interstate compact, and determine that the land is in Missouri.
Analysis:
This decision solidifies the principle of jurisdictional finality by extending it unequivocally to cases involving title to real property, a traditionally sensitive area of state sovereignty. It reinforces the policy that there must be an end to litigation, holding that a party who has a full and fair opportunity to contest subject-matter jurisdiction in the original forum cannot collaterally attack that determination in a subsequent proceeding. The case elevates the principles of res judicata and full faith and credit over the potential for a second court to correct a jurisdictional error, thereby promoting certainty and finality in judgments across state lines.
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