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← 214 F.3d 865 - Mark A. Ramsden v. Agribank

Mark A. Ramsden v. Agribank’s Empirical Analysis

2000

Citation profile

7
cited by 7 later decisions
1
states following
August 2016
most recently cited

1 district · 1 state decisions

Relationships

Relies on Daubert v. Merrell Dow Pharmaceuticals, Inc. · Younger v. Harris · Kremer v. Chemical Construction Corp. · Atlantic Coast Line Railroad v. Brotherhood of Locomotive Engineers · Mitchum v. Foster

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[The Supreme Court] reached this conclusion after noting that the Full Faith and Credit Act, 28 U.S.C. § 1738 , under which a federal court must give the same preclusive effect to a state court judgment that another court of that state would give, embodies Congress’ legislative commitment to federalism and comity in the area of judgment recognition. 474 U.S. at 535 , 106 S.Ct. 768 . The Parsons Steel Court went on to hold that “the Anti Injunction Act and the Full Faith and Credit Act can be construed consistently, simply by limiting the relitigation exception of the Anti Injunction Act to those situations in which the state court has not yet ruled on the merits of the res judicata issue.” 474 U.S. at 524 , 106 S.Ct. 768 . It further explained that “the Full Faith and Credit Act requires that federal courts give the state-court judgment, and particularly the state court’s resolution of the res judicata issue, the same preclusive effect it would have had in another court of the same State.” Id. at 525 , 106 S.Ct. 768 . In other words, a federal court considering enjoining a state court proceeding, where the state court has ruled on the res judicata issue, must first, as a threshold matter, look to that state’s law of judgments to determine whether another court of that state would view the res judicata ruling as final and binding. If so, then the federal court is bound by that ruling as well.”
    2 later decisions quote this exact passage · from the majority
  2. “Any federal injunction to bar purported relitigation balances efficiency advantages of finality against respect for state courts and their decisions. Once a state court considers a res judicata defense and rules that a prior federal judgment does not actually bar a claim, the affront of federal court intervention stripping the state court of power to continue is greatly magnified. After such a ruling, the interests in preventing possible relit-igation are therefore generally outweighed by the heightened comity concerns except in the most extraordinary circumstances.”
    2 later decisions quote this exact passage · from the majority
  3. “comityD and federalism that must restrain a federal court when asked to enjoin a state court proceeding.”
    2 later decisions quote this exact passage · from the majority

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.