## Facts

- Dr. Ethel D. Migra worked for the Warren (Ohio) City School District under annual written contracts from 1976 to 1979.
- On April 17, 1979, the Board unanimously adopted a resolution renewing her employment for the 1979–1980 school year.
- Migra accepted the appointment by letter dated April 18 (delivered April 23).
- At a special meeting on April 24, 1979, the Board voted 3–1 not to renew her employment and notified her; she never received a written contract for 1979–1980.
- Migra sued in Ohio state court alleging (1) breach of contract by the Board and (2) wrongful interference by individual Board members.
- The state trial court found a binding contract existed for 1979–1980, ordered reinstatement and compensatory damages, and dismissed without prejudice an additional reserved issue concerning conspiracy and individual board member liability.
- Ohio appellate courts affirmed the judgment; further state review was denied.
- After the state case ended, Migra sued in federal court under 42 U.S.C. §§ 1983 and 1985 against the Board, board members, and the superintendent, alleging nonrenewal was retaliation for her activities relating to desegregation planning and curriculum work, violating the First, Fifth, and Fourteenth Amendments.
- The federal district court granted summary judgment for defendants on res judicata grounds; the Sixth Circuit affirmed.

## Issues

1. Whether 28 U.S.C. § 1738 requires a federal court to give a state-court judgment the same claim-preclusive effect it would receive in the rendering state, even when the later action asserts § 1983 claims not raised in the state suit.
2. Whether § 1983 creates an implied exception to § 1738 or to ordinary state-law claim preclusion rules.

## Decision

- The Supreme Court affirmed the Sixth Circuit.
- Federal courts must give a state-court judgment the same claim-preclusive effect it would have in the state’s own courts, including as to later § 1983 claims that were not litigated in the state action.
- Section 1983 does not create an implied exception to § 1738’s full-faith-and-credit command.
- The scope of claim preclusion is determined by the rendering state’s law; the federal court must apply that state standard to decide whether the federal civil-rights claims are barred.

## Legal Principles

- Under 28 U.S.C. § 1738, state judicial proceedings must receive in federal court the same preclusive effect they would receive in the courts of the state that rendered the judgment.
- Section 1983 does not displace ordinary preclusion doctrine; absent a federal statutory modification, § 1738 governs preclusion in federal § 1983 litigation.
- Claim preclusion can bar not only claims actually litigated, but also claims that state law treats as arising from the same cause of action and that could have been raised in the earlier suit.
- The distinction between issue preclusion and claim preclusion does not justify different treatment under § 1738; both may apply in § 1983 cases when state law would apply them.
- A plaintiff who chooses to litigate a dispute in state court may forfeit a later federal forum for additional federal claims if state claim-preclusion rules require joinder.

## Conclusion

The Court held that § 1738 requires federal courts to apply the rendering state’s claim-preclusion law to a prior state judgment, and that § 1983 provides no implied exception allowing a plaintiff to relitigate in federal court federal civil-rights claims that state law would treat as barred because they could have been brought in the earlier state action.


Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984)