Gannon v. American Home Products, Inc.

Summary

The New Jersey Supreme Court reviews a product-liability action alleging that a polio vaccine caused brain cancer. The Court holds that federal law governs the collateral-estoppel effect in state court of the prior federal judgment rejecting the plaintiffs’ causation evidence, and reverses the Appellate Division. The Court does not reach the sufficiency of the plaintiffs’ product-identification evidence.

Holdings

1. The preclusive effect in a state-court proceeding of a judgment rendered by a federal court is determined under federal, not state, collateral-estoppel principles.
2. The federal judgment precluded plaintiffs from relitigating general and specific causation because the identical issues were decided, the federal judgment was final and on the merits, the parties were the same or in privity, and plaintiffs had a full and fair opportunity to litigate those issues.
3. The equitable considerations identified in Restatement (Second) of Judgments sections 28 and 29 did not permit plaintiffs to relitigate causation after a full and fair adjudication of that issue.

Questions Presented

1. Whether federal or New Jersey law governs the collateral-estoppel effect in New Jersey of a judgment rendered by a federal court.
2. Whether plaintiffs had a full and fair opportunity to litigate general and specific causation in the prior federal proceeding.
3. Whether equitable considerations under Restatement (Second) of Judgments sections 28 and 29 permitted plaintiffs to relitigate causation despite the prior federal judgment.

Disposition

reversed