Migra v. Warren City School Dist. Bd. of Educ

In Migra v. Warren City School Dist. Bd. of Educ., 465 U.S. 75, 104 S.Ct. 892, 79 L.Ed.2d 56 (1984), the Court faced the issue of whether the holding in Allen that 28 U.S.C. section 1738 obligated federal courts to apply state issue preclusion rules to determine whether the issue preclusive effect of a prior state court judgment in a section 1983 action should be extended to claim preclusion. The Migra Court concluded that "if Sec. 1983 created an exception to the general preclusive effect accorded to state-court judgments, such an exception would seem to require similar treatment of both issue preclusion and claim preclusion." Migra, 465 U.S. at 84, 104 S.Ct. at 897.