United States v. Moser
266 U.S. 236 (1924)
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Rule of Law:
The doctrine of issue preclusion (collateral estoppel) bars the re-litigation of a specific right, question, or fact that was actually litigated and determined in a prior action between the same parties, even if the second suit is for a different cause of action and the initial determination was based on an erroneous application of the law.
Facts:
- Moser served as a cadet at the U.S. Naval Academy during the Civil War.
- A federal statute (§ 11 of the Navy Personnel Act of 1899) allowed officers with a creditable record who 'served during the civil war' to retire with the rank and pay of the next higher grade.
- After serving for forty years, Moser retired from the Navy with the rank of Captain.
- Moser sought retirement pay equivalent to a Rear Admiral, the next higher grade, based on his belief that his time as a cadet constituted 'service during the civil war' under the statute.
Procedural Posture:
- Moser brought three separate, prior suits against the United States in the Court of Claims for installments of his retirement pay.
- In each of the three prior suits, the Court of Claims ruled in favor of Moser, finding that his status as a Civil War veteran had been established and was res judicata after the first case.
- Moser filed the present (fourth) suit against the United States in the Court of Claims seeking a new installment of pay.
- The Court of Claims again ruled in favor of Moser, holding that the United States was barred by the doctrine of res judicata from re-litigating his status as a Civil War veteran.
- The United States (appellant) appealed the decision of the Court of Claims to the Supreme Court of the United States, with Moser as the appellee.
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Issue:
Does the doctrine of res judicata prevent the United States from re-litigating the question of a naval officer's status as a Civil War veteran in a suit for a salary installment, when that same question of status was definitively decided between the same parties in a prior suit for an earlier salary installment?
Opinions:
Majority - Justice Sutherland
Yes. The doctrine of res judicata prevents the government from re-litigating the question of Moser's status. Because this suit is for a different cause of action (a new salary installment) than the previous suits, the applicable principle is issue preclusion. The specific question of whether Moser's service at the Naval Academy qualified him as an officer who 'served during the civil war' was the central issue expressly litigated and adjudged in his favor in three preceding suits against the same party, the United States. A right, question, or fact distinctly decided in one action cannot be disputed in a subsequent action between the same parties. While res judicata does not apply to unmixed questions of law, a determination of an individual's legal status, upon which his right to recover depends, is a 'question or right' that is conclusive, even if the original determination was based on an erroneous view of the law.
Analysis:
This case clarifies the scope and application of issue preclusion (collateral estoppel), a branch of res judicata. It establishes that a judicial determination of a person's legal status, which is often a mixed question of law and fact, is considered a 'question or right' that, once decided, cannot be re-litigated between the same parties in subsequent claims. This decision reinforces the principle of judicial finality, preventing parties from endlessly challenging a settled issue every time a new, related claim arises. The ruling underscores that the preclusive effect applies even if the original court's legal reasoning is later deemed incorrect, prioritizing finality over the correction of potential past errors in litigation between the same parties.
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