| Venue: | SCOTUS |
| Facts: | It's a fight over who owns the land. Problem is that the land is right on the NE/MO border, which is the MO river. Who will win will depend on whether the river moved swiftly (avulsion) or slowly (accretion). But careful! The same determination would also decide which court has jurisdiction! |
| Posture: | Suit in NE court, Duke fully ligitates the issues and explicitly contests jurisdiction. Durfee wns. Duke appeals, and NE SC affirms. Then Duke files suit in MO court. Removed to federal district court on diversity. District court finds that the land is in MO, but the NE court's decision is binding because of res judicata. Reversed on appeal: no need for full faith and credit if NE court lacked jurisdiction. Cert granted. |
| Issue: | Does a prior court's determination of its own jurisdiction merit full faith and credit? |
| Holding: | Yes. Reversed. |
| Rule: | If the issue of jurisdiction has been fully and fairly litigated, it is entitled to respect. |
| Reasoning: | Public policy dictates that there should be an end to litigation.
And Duke didn't appeal to SCOTUS after the NE SC decision. |
| Dicta: | |