3.1 Precedents Cited

The judgment references several key precedents that influenced the court’s decision:

• Migra v. Warren City Sch. Dist. Bd. of Educ. (1984) – Outlined the requirements under the Full Faith and Credit Act for preclusive effects in federal courts.
• SEDLEY v. CITY OF WEST BUECHEL (1971) – Highlighted the boundaries of preclusive effect, emphasizing that only matters necessarily involved and determined in prior actions are estopped.
• ROOKER v. FIDELITY TRUST CO. (1923) and District of Columbia Court of Appeals v. Feldman (1983) – Established the Rooker-Feldman doctrine, restricting lower federal courts from serving as appellate bodies for state court decisions.
• Heyliger v. State Univ. and Cmty. Coll. Sys. of Tenn. (1997) – Provided guidance on reviewing preclusion doctrines de novo in federal appellate courts.

3.2 Legal Reasoning

The court meticulously dissected the applicability of issue preclusion and claim preclusion under Kentucky law, alongside evaluating the relevance of the Rooker-Feldman doctrine:

• Issue Preclusion: For Chipman’s substantive due process claim, the court determined that the prior state court judgments did not foreclose his federal claim because the specific issue of custody at the time of the fatal accident was dicta, not a necessary part of the state court’s judgment.
• Claim Preclusion: The court found that Chipman’s federal claims were distinct from his prior state wrongful death actions, thereby not barred by claim preclusion which requires identical causes of action.
• Rooker-Feldman Doctrine: The court held that this doctrine did not apply as Chipman was not merely attempting to appeal the state court's judgment but was asserting a separate federal substantive due process claim.
• Regarding Stemler’s equal protection claim, the court affirmed that issue preclusion applied based on the state court’s explicit findings against improper motive in her arrest, thereby barring her federal claim.
• For Stemler's excessive force and falsification of evidence claims, the court recognized that these issues were not addressed or decided in state courts, allowing the federal court to entertain them without invoking preclusive doctrines.

3.3 Impact

This judgment has significant implications for future § 1983 litigation, particularly in delineating the boundaries of preclusive doctrines:

• Affirms that federal courts must carefully assess whether preclusive effect applies based on the necessity and finality of prior state court findings.
• Clarifies that claims under different legal theories or causes of action are not precluded even if arising from the same factual circumstances.
• Reiterates the limited scope of the Rooker-Feldman doctrine, emphasizing that federal courts can adjudicate federal claims that are not merely attempts to overturn state court decisions.

4.1 Issue Preclusion

Issue Preclusion, also known as collateral estoppel, prevents parties from relitigating issues that have already been conclusively settled in previous litigation. For it to apply, the issue must have been essential to the prior judgment, actually litigated, and necessarily decided.

4.2 Claim Preclusion

Claim Preclusion, or res judicata, bars parties from suing on the same cause of action in multiple lawsuits once a final judgment has been rendered. It requires identity of parties, causes of action, and a decision on the merits.

4.3 Rooker-Feldman Doctrine

The Rooker-Feldman Doctrine prohibits lower federal courts from reviewing state court decisions. It ensures that only the Supreme Court can resolve issues of state court judgments in federal courts.