## Facts

- Willie McCurry was prosecuted in Missouri state court for heroin possession.
- McCurry moved to suppress heroin and other evidence, alleging an unconstitutional search and seizure under the Fourth and Fourteenth Amendments.
- After a suppression hearing, the trial court denied the motion in relevant part, finding no Fourth Amendment violation.
- McCurry was convicted by a jury; the Missouri Court of Appeals affirmed.
- McCurry did not claim he lacked a full and fair opportunity to litigate his Fourth Amendment claim in state court; federal habeas review of that Fourth Amendment claim was therefore unavailable under Stone v. Powell.
- McCurry filed a federal damages action under 42 U.S.C. § 1983 against St. Louis police officers and related officials, again alleging the search and seizure violated the Fourth Amendment.
- The federal district court granted summary judgment for defendants, holding collateral estoppel barred relitigation of the Fourth Amendment issue decided in state court.
- The Eighth Circuit reversed, reasoning that because habeas review was unavailable, § 1983 should provide access to a federal forum without issue preclusion.

## Issues

1. Whether a state court’s rejection of a criminal defendant’s Fourth Amendment suppression claim can collaterally estop the defendant from relitigating the same issue in a later federal § 1983 damages action.
2. Whether the unavailability of federal habeas review for a fully and fairly litigated Fourth Amendment claim prevents application of collateral estoppel in a subsequent § 1983 suit.
3. Whether § 1983’s text or history indicates Congress intended to displace ordinary preclusion rules for issues decided in state criminal proceedings.

## Decision

- The Supreme Court reversed the Eighth Circuit and remanded.
- The Court held that § 1983 does not generally bar application of collateral estoppel to issues previously decided in state court.
- The Court held that the inability to obtain federal habeas relief on a Fourth Amendment claim does not make collateral estoppel inapplicable to a § 1983 action.
- Because McCurry had a full and fair opportunity to litigate the Fourth Amendment issue in state court (and did not contend otherwise), the state court determination could preclude relitigation in federal court.

## Legal Principles

- Federal courts apply ordinary preclusion rules, including collateral estoppel, to prevent relitigation of issues of fact or law that were necessarily decided in prior proceedings involving the same party.
- A § 1983 claim does not carry an automatic entitlement to relitigate in federal court a constitutional issue already adjudicated in state court.
- Nothing in § 1983’s text or legislative history shows congressional intent to deny preclusive effect to state-court judgments, including judgments arising from state criminal proceedings, when the state court acted within its jurisdiction.
- Collateral estoppel applies only if the party against whom it is asserted had a full and fair opportunity to litigate the issue in the earlier proceeding.
- Limits on federal habeas review of Fourth Amendment claims do not create an exception to preclusion doctrine for § 1983 damages actions.

## Conclusion

The Court held that a state criminal court’s resolution of a Fourth Amendment search-and-seizure issue may bar relitigation of that issue in a later federal § 1983 damages suit when the defendant previously had a full and fair opportunity to litigate it, and the lack of habeas review does not change that result.


Allen v. McCurry, 449 U.S. 90 (1980)