Migra v. Warren City School District Board of Education
465 U.S. 75 (1984)
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Rule of Law:
A state-court judgment has the same claim preclusive effect in a subsequent federal civil rights suit under 42 U.S.C. § 1983 as it would have in the courts of the state where the judgment was rendered. This preclusion applies not only to issues actually litigated but also to claims that could have been raised in the prior state action.
Facts:
- Dr. Ethel D. Migra was employed as a supervisor of elementary education by the Warren City School District Board of Education.
- On April 17, 1979, the Board unanimously voted to renew Migra's employment for the upcoming school year.
- Migra accepted the renewal in writing on April 18 and delivered the acceptance on April 23.
- On April 24, the Board held a special meeting and, by a 3-to-1 vote, rescinded its prior decision and chose not to renew Migra's employment.
- Migra was subsequently notified of her termination and did not receive a contract for the 1979-1980 school year.
- Migra later alleged the nonrenewal was retaliation for her work on a school desegregation plan and a related curriculum, which she claimed was an exercise of her First Amendment rights.
Procedural Posture:
- Dr. Migra sued the Board and three members in the Court of Common Pleas of Trumbull County, Ohio (a state trial court), for breach of contract and wrongful interference.
- The state trial court ruled for Migra on the breach of contract claim, awarding reinstatement and damages, but did not reach the other claims.
- Upon Migra's motion, the trial court dismissed the remaining claims against the individual members without prejudice.
- The Ohio Court of Appeals (an intermediate appellate court) affirmed the judgment.
- The Supreme Court of Ohio (the state's highest court) denied review.
- Migra then filed a new lawsuit in the U.S. District Court for the Northern District of Ohio, asserting federal claims under 42 U.S.C. §§ 1983 and 1985.
- The defendants moved for, and the District Court granted, summary judgment on res judicata grounds.
- The U.S. Court of Appeals for the Sixth Circuit affirmed the District Court's dismissal.
- The U.S. Supreme Court granted certiorari to resolve the issue.
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Issue:
Does a state court judgment have the same claim preclusive effect in a subsequent federal § 1983 lawsuit as it would in the rendering state's own courts, thereby barring claims that could have been, but were not, raised in the state proceeding?
Opinions:
Majority - Justice Blackmun
Yes. A state-court judgment must be given the same claim preclusive effect in a subsequent federal § 1983 action as it would be given by the courts of the rendering state. The federal full faith and credit statute, 28 U.S.C. § 1738, requires federal courts to give state-court judgments the same effect they would have in their own state. In Allen v. McCurry, the Court held § 1983 does not create an exception to § 1738 for issue preclusion, and the same reasoning applies to claim preclusion. There is no basis to distinguish between issues that were litigated and claims that could have been litigated; any distrust of state courts underlying § 1983 would apply to both. The policies of comity, finality, and judicial economy embodied in § 1738 override a plaintiff's desire to split claims between state and federal forums.
Concurring - Justice White
Yes. Justice White concurred in the judgment, agreeing that longstanding precedent requires federal courts to apply state preclusion law. However, he wrote separately to express that he believes this construction of § 1738 is 'unfortunate.' He argued that federal courts should be free to apply their own, potentially broader, res judicata rules, as the purpose of § 1738 is to ensure state judgments are given effect, not to limit the preclusive effect a federal court might otherwise provide. Nevertheless, because the contrary construction is of long standing and Congress has not acted to change it, he joined the Court's opinion.
Analysis:
This decision solidified and extended the Court's holding in Allen v. McCurry, which applied issue preclusion to § 1983 cases. Migra confirms that claim preclusion also applies, effectively preventing litigants from 'claim splitting'—suing on state-law grounds in state court and then filing a separate federal civil rights action based on the same underlying facts. The ruling forces plaintiffs to choose their forum and bring all related claims in a single proceeding. It reinforces principles of comity and finality, requiring federal courts to give full effect to state court adjudications, thereby conserving judicial resources and preventing vexatious litigation.
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