Federal Judgments in State Courts

The Full Faith and Credit Clause of the Constitution or the full faith and credit statute (28 U.S.C. § 1738) does not provide for federal judgments in a state court.  Nevertheless, a series of Supreme Court cases filled the gap by reading the full faith and credit statute to require state courts to respect federal judgments. For example, in Dawson v. Estate of Ott the court of appeals stated that as a basic rule, where a judgment or decree of a federal court determines a right under a federal statute, the decision is final until reversed in an appellate court or modified or set aside in the court of its rendition.  Moreover, state courts generally accept the rule that they must give full faith and credit to the proceedings of federal courts and the court held that state courts are ‘destitute of all power’ to interfere with the decisions or proceedings of federal courts.

Further, in Setek Int’l Inc. v. Lockheed Martin Corp., the Supreme Court of United States held that federal question judgments have effect under the federal preclusion doctrine.  It stated that preclusive effect of federal diversity judgments must be determined by the intramural preclusion law of the state where the federal court rendering the judgment was sitting.

Inside Federal Judgments in State Courts