Issue Preclusion Doctrine
The doctrine of issue preclusion represents a choice between the competing values of correctness, uniformity, and repose. Further examination of an issue once decided may yield a better informed result, but that is not necessarily the case. Nevertheless, judicial efficiency requires that there be an end to litigation at some point.
"Courts to determine the rights of parties are an integral part of our system of government. It is just as important that there should be a place to end as that there should be a place to begin litigation.
After a party has his day in court, with opportunity to present his evidence and his view of the law, a collateral attack upon the decision as to jurisdiction there rendered merely retries the issue previously determined.
There is no reason to expect that the second decision will be more satisfactory than the first." ( Stoll v. Gottlieb (1938) 305 U.S. 165, 172 [59 S. Ct. 134, 138, 83 L. Ed. 104].)
Our system resolves the conflict between these competing values by holding that an issue once determined normally may not be reexamined in a later proceeding.
Here we are required to ascertain the issue that was determined as a result of a prior action, from which an appeal was taken to a higher court, which filed its own decision.
Article IV, section 1 of the United States Constitution commands that "Full Faith and Credit shall be given in each state to the public acts, records, and judicial proceedings of every other state."
How this clause came to mean that that the scope and effect of a federal judgment are identical to those of a judgment of a court of the state in which the federal judgment is rendered is traced in Degnan, Federalized Res Judicata (1976) 85 Yale L.J. 741, 742-749.
The relationship between the full faith and credit clause and the doctrine of res judicata was addressed by Chief Justice Stone in Magnolia Petroleum Co. v. Hunt (1943) 320 U.S. 430, 439-440 [64 S. Ct. 208, 214, 88 L. Ed. 149, 150 A.L.R. 413], as follows:
"The clear purpose of the full faith and credit clause is to establish throughout the federal system the salutary principle of the common law that a litigation once pursued to judgment shall be as conclusive of the rights of the parties in every other court as in that where the judgment was rendered, so that a cause of action merged in a judgment in one state is likewise merged in every other. . . . Because there is a full faith and credit clause a defendant may not a second time challenge the validity of the plaintiff's right which has ripened into a judgment and a plaintiff may not for his single cause of action secure a second or a greater recovery."