Durfee v. Duke
Citation and Court
375 U.S. 106 (1963), Supreme Court of the United States
Facts
A Nebraska court adjudicated the ownership of land located on the Missouri-Nebraska border and determined the land was in Nebraska, giving Durfee title. Duke had fully litigated the jurisdictional question (whether the land was in Nebraska) in the Nebraska proceedings and lost. Duke then filed a new suit in Missouri seeking to challenge Nebraska’s jurisdiction to adjudicate title to what Duke claimed was Missouri land.
Issue
Whether Missouri must give full faith and credit to the Nebraska judgment on land title, even though Missouri courts might disagree about whether the land is located in Nebraska and thus subject to Nebraska’s jurisdiction.
Holding
Missouri must give full faith and credit to the Nebraska judgment; once subject-matter jurisdiction was fully and fairly litigated in the first proceeding, it cannot be re-litigated collaterally in another state’s courts.
Rule / Doctrine
Full faith and credit extends to a court’s determination of its own subject-matter jurisdiction when that jurisdictional question was actually litigated and decided in the prior proceeding. A party who has had a full and fair opportunity to contest jurisdiction in the first forum may not relitigate that question collaterally in a second forum.
Significance
Durfee v. Duke establishes that actually litigated jurisdictional findings receive full faith and credit, preventing losing parties from making collateral attacks on sister-state judgments by claiming the first court lacked jurisdiction. It is paired with the default judgment cases where jurisdiction was not contested.