Marrese v. American Academy of Orthopaedic Surgeons Case Brief

Why is the case important?

The Plaintiffs, two orthopedic surgeons (Plaintiffs), sued the Defendant, the American Academy of Orthopaedic Surgeons (Defendant) alleging they were refused membership in the Academy without a hearing. In the course of discovery, the Plaintiffs asked the Defendant for correspondence and other documents relating to the denial of applications from 1970-1980. Despite a federal court order which would protect the confidentiality of the documents, the Defendant refused to comply and was held in criminal contempt.

Facts of the case

Question

Whether the files of voluntary organizations are discoverable in appropriate circumstances, subject to appropriate safeguards.

Answer

Yes. Here the discovery order issued by the district court judge was erroneous and did not safeguard the confidentiality of Defendant’s files thoroughly.

Conclusion

Although federal antitrust claims are within the exclusive jurisdiction of the federal courts, the Court of Appeals ruled that the dismissal of petitioners’ complaints in state court barred them from bringing a claim based on the same facts under the Sherman Act. The Court of Appeals erred by suggesting that in these circumstances a federal court should determine the preclusive effect of a state court judgment without regard to the law of the State in which judgment was rendered.

  • Case Brief: 1985
  • Petitioner: Marrese
  • Respondent: American Academy of Orthopaedic Surgeons
  • Decided by: Burger Court

Citation: 470 US 373 (1985)
Argued: Dec 4, 1984
Decided: Mar 4, 1985