## Facts

- Retail purchasers of women’s clothing filed seven private antitrust suits in federal court against Federated Department Stores and others, alleging a price-fixing conspiracy and seeking class relief under federal antitrust law.
- The district court consolidated the cases and dismissed all seven actions for failure to allege “injury” to “business or property” under § 4 of the Clayton Act.
- Five plaintiff groups appealed; respondents Moitie and Brown did not.
- Moitie and Brown instead filed new actions in California state court based on substantially similar allegations, reframed as state-law claims.
- Defendants removed the refiled actions to federal court, where the district court dismissed them on res judicata (claim preclusion) grounds.
- After an intervening Supreme Court decision clarified that certain consumer injuries can qualify as “injury to business or property,” the Ninth Circuit reversed the dismissals in the five appealed actions and later reversed the res judicata dismissals for Moitie and Brown, reasoning that res judicata should yield to “public policy” and “simple justice” because their position was “closely interwoven” with that of the successful appellants.
- The Supreme Court granted review to determine whether such an equitable exception to res judicata was permissible.

## Issues

1. Whether a final, unappealed federal judgment on the merits bars plaintiffs from bringing a later suit based on the same cause of action after an intervening change in law.
2. Whether a court of appeals may create an equitable exception to res judicata based on “public policy,” “simple justice,” or the fact that nonappealing parties’ claims are “closely interwoven” with those of parties who successfully appealed.
3. Whether recharacterizing substantially similar allegations as state-law claims avoids claim preclusion where the earlier federal judgment was final and unappealed.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- Res judicata barred Moitie’s and Brown’s refiled actions because the earlier dismissals were final, on the merits, and unappealed as to them.
- The preclusive effect of a final, unappealed judgment is not diminished because the judgment may have been legally wrong or later undermined by a change in law.
- The Court rejected any general equitable exception allowing relitigation merely because nonappealing parties’ rights are “closely interwoven” with those of parties who appealed successfully or because “simple justice” might favor reopening the case.

## Legal Principles

- A final, unappealed judgment on the merits has full claim-preclusive effect, even if the legal rule applied is later overruled or materially altered.
- Claim preclusion is a doctrine of finality that binds parties to the consequences of litigation choices, including the choice not to appeal.
- Courts may not deny res judicata effect based on ad hoc equitable considerations such as “simple justice,” generalized “public policy,” or similarity to other parties who obtained appellate relief.
- Refiling substantially the same operative claims in a different forum or under different labels does not avoid claim preclusion when the earlier judgment is final and involves the same cause of action.

## Conclusion

The Court held that Moitie and Brown were bound by the final, unappealed dismissals of their earlier federal antitrust actions and could not relitigate by refiling similar claims after an intervening change in law; no equitable exception permits reopening final judgments based on fairness or related parties’ successful appeals.


Federated Dep’t Stores, Inc. v. Moitie, 452 U.S. 394 (1981)