Durfee v. Duke Case Brief

Why is the case important?

“Two property owners contested ownership of a piece of land situated along the Missouri River on the Nebraska and Missouri border. A Nebraska court ruled that the land in question was located in Nebraska and issued judgment as to the ownership of the land. The losing party then filed suit in Missouri, seeking to quiet title to the land.
Synopsis of Rule of Law. A judgment is entitled to full faith and credit, for res judicata purposes, even as to questions of jurisdiction, where the second court’s inquiry disclosed that those questions have been fairly and fully litigated and finally decided in the court which rendered the original judgment.”

Facts of the case

Question

Whether a state court judgment is entitled to full faith and credit for res judicata purposes even though a later court finds that the initial state court lacked jurisdiction over the suit.

Answer

Yes. The Supreme Court reversed the judgment of the court of appeals. Full faith and credit requires every state to give to a judgment at least the res judicata effect which the judgment would be accorded in the state which rendered it. A judgment is entitled to full faith and credit, even as to questions of jurisdiction, where the second court’s inquiry disclosed that those questions have been fairly and fully litigated and finally decided in the court which rendered the original judgment. Since the question of subject matter jurisdiction had been fully litigated in the original forum, the issue could not be retried in a subsequent action between the parties. Concurrence. Justice Thomas C. Black (J. Black) concurred. J. Black’s concurrence stated that he would not uphold the judgment of the Nebraska court if it were later found that the land in question was actually located in Nebraska because no state has power to make a determination binding on the other as to which state the land is in.

Conclusion

The United States Supreme Court granted certiorari and reversed the judgment because the federal court in Missouri had the power and, upon proper averments, the duty to inquire into the jurisdiction of the Nebraska courts to render the decree quieting title to the land in petitioners. The Court held that when that inquiry disclosed, as it did, that the jurisdictional issues had been fully and fairly litigated by the parties and finally determined in the Nebraska courts, the federal court in Missouri was correct in ruling that further inquiry was precluded.

  • Case Brief: 1963
  • Petitioner: Durfee
  • Respondent: Duke
  • Decided by: Warren Court

Citation: 375 US 106 (1963)
Argued: Oct 24, 1963
Decided: Dec 2, 1963