## Facts

- EPA and Tennessee officials sought to inspect Stauffer Chemical Company’s Tennessee plant under the Clean Air Act, accompanied by private contractor employees working under contract to EPA.
- Stauffer refused to permit the contractors to enter unless they agreed not to disclose trade secrets; the contractors declined.
- EPA obtained an administrative warrant authorizing the private contractor employees to conduct the inspection.
- Stauffer continued to refuse entry to the private contractors, and the United States initiated a civil contempt proceeding in federal district court.
- Stauffer moved to quash the warrant, arguing (1) private contractors were not “authorized representatives” under Clean Air Act § 114(a)(2) and (2) the United States was collaterally estopped from relitigating that issue due to a prior Tenth Circuit decision involving the same parties and similar inspection facts at Stauffer’s Wyoming plant.
- The district court denied the motion to quash, rejecting collateral estoppel and accepting the Government’s statutory interpretation.
- The Sixth Circuit reversed, holding for Stauffer on the merits and, alternatively, on collateral estoppel.
- The Supreme Court granted review limited to whether the Government was collaterally estopped from relitigating the statutory issue.

## Issues

1. Whether the United States may be barred by mutual defensive collateral estoppel from relitigating, against the same party, an identical statutory question previously decided against it in a case involving virtually identical facts.
2. Whether any exception for “unmixed questions of law” or asserted regulatory/public importance prevents applying collateral estoppel to the Government on these facts.

## Decision

- The Supreme Court affirmed the Sixth Circuit on collateral estoppel grounds.
- The Court held that mutual defensive collateral estoppel applies against the Government to preclude relitigation of an issue already litigated and decided against it with the same party in a case involving virtually identical facts.
- The Court did not decide the underlying statutory meaning of “authorized representatives” under § 114(a)(2).
- The Court rejected applying an “unmixed questions of law” exception because the successive actions were not unrelated and arose from virtually identical factual circumstances.
- The Court declined to create a broad exception based on the claimed public importance of recurring regulatory issues, noting the Government could litigate the question against different parties.

## Legal Principles

- Issue preclusion bars relitigation of issues of law and fact conclusively determined in a prior action involving the same parties.
- The United States is generally subject to mutual defensive collateral estoppel when the same party and the same issue are presented on materially indistinguishable facts.
- Any “unmixed question of law” limitation on estoppel is narrow and does not apply where successive actions involve the same parties and virtually identical factual settings.
- The possibility that an issue recurs in regulatory enforcement does not, by itself, justify exempting the Government from mutual defensive collateral estoppel.

## Conclusion

The Court held that the United States could not relitigate against Stauffer a statutory issue previously decided against the Government in earlier litigation between the same parties arising from virtually identical inspection facts, and it affirmed solely on collateral estoppel grounds without addressing the statute’s interpretation.


United States v. Stauffer Chem. Co., 464 U.S. 165 (1984)