Stemler v. Florence
United States Court of Appeals for the Sixth Circuit
350 F.3d 578 (6th Cir. 2003)
After a drunken altercation involving Susan Stemler, Conni Black, and Steve Kritis, police arrested Stemler and allegedly placed Black in Kritis's truck; Kritis drove off, and Black was killed in a crash. Black's estate administrator (plaintiff) sued the officers, city, and county sheriff (defendants) for wrongful death in state court, ultimately losing when the Kentucky Supreme Court held Black wasn't restrained or in custody when she died, adding in dicta that she was never in custody at all. The administrator then sued in federal court under 42 U.S.C. section 1983; the district court dismissed the claims against the officers and granted summary judgment to the city and county. On appeal, the Sixth Circuit initially treated the state court's custody rulings as preclusive and remanded; the district court then held the administrator was barred from relitigating whether Black was ever in custody, and the administrator appealed again.
Whether a state court's determination on an issue is entitled to preclusive effect in later federal litigation when that determination was not necessary to the state court's judgment.