470 U.S. 373 (U.S. 1985)
Marrese v. American Academy of Orthopaedic Surgeons is a cornerstone Supreme Court decision on the interaction between state-court judgments and subsequent federal litigation, especially where the federal claim lies within the exclusive jurisdiction of the federal courts (such as Sherman Act antitrust claims).
Must a federal court, under 28 U.S.C. § 1738, apply the rendering state's preclusion law to determine whether a prior state-court judgment bars a subsequent federal antitrust action falling within the exclusive jurisdiction of the federal courts, and, if so, is there a general exception to § 1738 for such exclusively federal claims?
Under 28 U.S.C. § 1738, federal courts must give state-court judgments the same full faith and credit that the rendering state's courts would give them. Therefore, the preclusive effect of a state judgment in a subsequent federal action is determined by the law of the state that rendered the judgment. If, under that state's preclusion principles, the later federal claim would be barred, the federal court must then ask whether the federal statute creating the cause of action expressly or impliedly creates an exception to § 1738. Exclusive federal jurisdiction, standing alone, does not itself create a blanket exception to § 1738.
The Court vacated the Seventh Circuit's judgment and remanded. The court of appeals erred in adopting a categorical rule that a state-court judgment cannot have claim-preclusive effect over a subsequent federal action that falls within the exclusive jurisdiction of the federal courts. Instead, the federal court must first look to the rendering state's law of preclusion and then consider whether the federal statute at issue overrides § 1738. No general antitrust exception to § 1738 was recognized.
Marrese is the leading case on how federal courts assess the preclusive effect of prior state-court judgments when the later claim is within exclusive federal jurisdiction. It instructs courts to: (1) apply the rendering state's law of preclusion; and (2) only if that law would bar the claim, determine whether the federal statute creates an exception to § 1738. The case underscores that exclusive federal jurisdiction does not automatically shield plaintiffs from claim preclusion and that litigation strategy in state court can have decisive consequences for later federal suits. It is frequently taught with Kremer and Migra to illustrate full faith and credit, claim preclusion, and the limits of federal common law in preclusion doctrine.