United States v. Throckmorton
98 U.S. 61 (1878) (1878)
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Rule of Law:
A court of equity will not set aside a final judgment for fraud that was intrinsic to the matters tried by the court, such as the use of perjured testimony or fraudulent documents. Relief is only available for extrinsic or collateral fraud, which is fraud that prevented the unsuccessful party from fully and fairly presenting their case.
Facts:
- W.A. Richardson was in possession of a tract of land in California under a claim from the Mexican government but lacked a final, formal grant document.
- In 1852, Richardson filed a petition with a U.S. board of commissioners to have his land claim validated.
- Believing his evidence was insufficient, Richardson traveled to Mexico and procured the signature of Micheltorena, a former governor, on a grant document.
- This grant was fraudulently antedated to appear as if it had been executed at a time when Micheltorena had the authority to issue such grants.
- Richardson submitted this antedated grant and supporting perjured testimony to the board of commissioners as evidence of his title.
- The claim was confirmed, and many years later, the land passed from Richardson's ownership to the defendants, Throckmorton and others.
Procedural Posture:
- On December 27, 1853, the Board of Commissioners of Private Land-Claims in California issued a decree confirming W.A. Richardson's claim.
- The United States appealed this decree to the U.S. District Court for the District of California.
- On February 11, 1856, the District Court affirmed the commissioners' decree.
- The United States then appealed the District Court's decision to the Supreme Court of the United States.
- On April 2, 1857, the U.S. Attorney-General ordered the appeal to be dismissed, making the confirmation of Richardson's claim final.
- Over twenty years later, on May 13, 1876, the United States filed a bill in equity in the U.S. Circuit Court to set aside the prior decrees on the basis of fraud.
- The defendants (Throckmorton et al.) filed a demurrer to the bill, which the Circuit Court sustained, dismissing the case on the merits.
- The United States appealed the Circuit Court's dismissal to the Supreme Court of the United States.
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Issue:
Does a court of equity have the power to set aside a final judgment obtained through the use of a fraudulent document and perjured testimony, when the authenticity of that document and the truth of the testimony were the very issues decided in the original case?
Opinions:
Majority - Mr. Justice Miller
No. A final judgment rendered by a court of competent jurisdiction cannot be annulled in a separate proceeding for fraud related to matters that were actually presented and considered by the court. The principle of finality in litigation dictates that acts for which a court of equity will set aside a judgment must be frauds that are extrinsic or collateral to the matter tried, not fraud in the matter on which the decree was rendered. Extrinsic fraud is conduct that prevents a party from presenting their case, such as keeping a party away from court through a false promise of a compromise or an attorney corruptly selling out their client. In contrast, intrinsic fraud, such as the use of a fraudulent instrument or perjured evidence, is not a basis for setting aside a judgment because the truth of that evidence was the very matter the court was tasked with determining. To allow judgments to be challenged on the basis of intrinsic fraud would lead to endless litigation, as the losing party could always claim the evidence was false. Here, the genuineness of the Micheltorena grant was the central question before the original tribunals; therefore, the alleged fraud was intrinsic and the judgment is final.
Analysis:
This case establishes the seminal distinction between intrinsic and extrinsic fraud as the basis for challenging a final judgment. By prioritizing the public policy of finality in litigation (res judicata), the Throckmorton rule creates a high bar for parties seeking to vacate a judgment on grounds of fraud. The decision mandates that the fraud must have prevented a true adversarial contest from ever happening, rather than simply involving dishonesty within the contest itself. This doctrine profoundly shapes modern civil procedure, limiting the circumstances under which a concluded case can be reopened and reinforcing the principle that parties are expected to uncover fraud during the original litigation.
