Geldermann, Inc. v. Commodity Futures Trading Commission

How later courts describe this case

• state court result will bind federal prosecutors only if they “substantially controlled]” the state action or were “virtually represented]” by the state prosecutor
• “The express language of this subsection suggests that the priority or lien granted thereunder is limited to securing the newly incurred debt authorized by that provision.”
• denial of a continuance by a district court will not be reversed absent a clear showing of abuse of discretion
• privity can be established for purposes of collateral estoppel by virtual representation