Brooks v. Department of Health & Human Services

How later courts describe this case

• indicating that federal law of preclusion should be applied when a federal court is determining the preclusive effect of another federal court's ruling
• noting that § 504 of the Rehabilitation Act does not explicitly require exhaustion of administrative remedies, but concluding that Congress intended remedies and procedures under § 501 and § 504 to be the same
• applying federal preclusion law where the previous action was in federal court under federal question jurisdiction, and extending it to prior diversity jurisdiction judgments in dicta
• noting importance of appellate review in receiving full and fair opportunity to litigate
• dismissal of pro se habeas petition for abuse of the writ is proper only where petitioner subjectively knew about a particular claim when the earlier petition was filed
• “It would seem that federal courts must possess an equivalent power and that federal law should determine the preclusive effect of a federal judgment, without regard to the basis of jurisdiction.”
• "[I]f an appeal is taken and the appellate court affirms on one ground and disregards the other, there is no collateral estoppel as to the unreviewed ground."