Presently before the Court is Plaintiff’s Petition for Declaratory Judgment (#1).
I. Background
On June 14, 2014, Plaintiff XXXXX (Plaintiff) obtained a judgment against
Defendant XXXXX (Defendant) from the Las Vegas Justice Court. The court awarded Plaintiff
$6,700, which Defendant has yet to pay. Plaintiff filed the present petition on January 14, 2015,
citing both the Nevada Uniform Declaratory Judgment Act and the Declaratory Judgment Act, 28
U.S.C.A. § 2201.
III. Analysis
A. Res Judicata
The doctrine of res judicata bars Plaintiff’s Petition for a Declaratory Judgment. “Under res
judicata, a final judgment on the merits of an action precludes . . . relitigating issues that were or
XXXX v. XXXXX Doc. 6
(withheld)
could have been raised in that action.” Allen v. McCurry, 449 U.S. 90, 94 (U.S. 1980) (citation
omitted). Specifically, Congress requires all federal courts “to give preclusive effect to state-court
judgments whenever the courts of the State from which the judgments emerged would do so.” Id at
96; see also 28 U. S. C. § 1738 ("[Judicial] proceedings [of any court of any State] shall have the
same full faith and credit in every court within the United States and its Territories and Possessions
as they have by law or usage in the courts of such State.").
Plaintiff obtained a judgment against Defendant from the Las Vegas Justice Court on June 14,
2014, awarding him $6,700. Plaintiff requests this Court grant him a declaratory judgment in the
amount of $46,900, attributing the increase from his original judgment to compensatory and punitive
damages. However, res judicata precludes this Court from creating a second judgment based on
claims already adjudicated by the Las Vegas Justice Court.1
“To take such a step would constitute a
denial of that full faith and credit which a federal court should give to the acts of a state court.”
Huron Holding Corp. v. Lincoln Mine Operating Co., 312 U.S. 183, 194 (1941).
B. Plaintiff’s Petition Does Not Meet Declaratory Judgment Requirements
Regardless of procedural bars, Plaintiff’s petition for a declaratory judgment is without merit,
as it does not meet the requirements of 28 U.S.C.A. § 2201.
1. Amount in Controversy
The amount in controversy required for the Court to issue a declaratory judgment is
$50,000. See 28 U.S.C.A. § 2201. The total judgment Plaintiff wishes to enforce is only $6,700.
Even accepting Plaintiff’s unsupported claim to seven times the original judgment only brings his
requested total to $46,900, which falls below the amount required by the statute.
2. Specific Language of Statute
28 U.S.C.A. § 2201(a) states, “In a case of actual controversy within its jurisdiction . .
. any court of the United States, upon the filing of an appropriate pleading, may declare the rights and
1
Plaintiff’s inability to enforce his judgment in this Court does not bar enforcement through proper means
other legal relations of any interested party seeking such declaration, whether or not further relief is
or could be sought.” Here, there is no actual controversy in existence, as the Las Vegas Justice Court
has already issued a judgment on all of Plaintiff’s claims. Further, Plaintiff does not seek a
declaration of his rights or legal relations, but rather seeks enforcement of a previously declared
judgment– an action distinct from what the specific language of § 2201(a) provides. As analyzed
supra, this Court has no authority to enforce Plaintiff’s state court judgment.
I. Background
On June 14, 2014, Plaintiff XXXXX (Plaintiff) obtained a judgment against
Defendant XXXXX (Defendant) from the Las Vegas Justice Court. The court awarded Plaintiff
$6,700, which Defendant has yet to pay. Plaintiff filed the present petition on January 14, 2015,
citing both the Nevada Uniform Declaratory Judgment Act and the Declaratory Judgment Act, 28
U.S.C.A. § 2201.
III. Analysis
A. Res Judicata
The doctrine of res judicata bars Plaintiff’s Petition for a Declaratory Judgment. “Under res
judicata, a final judgment on the merits of an action precludes . . . relitigating issues that were or
XXXX v. XXXXX Doc. 6
(withheld)
could have been raised in that action.” Allen v. McCurry, 449 U.S. 90, 94 (U.S. 1980) (citation
omitted). Specifically, Congress requires all federal courts “to give preclusive effect to state-court
judgments whenever the courts of the State from which the judgments emerged would do so.” Id at
96; see also 28 U. S. C. § 1738 ("[Judicial] proceedings [of any court of any State] shall have the
same full faith and credit in every court within the United States and its Territories and Possessions
as they have by law or usage in the courts of such State.").
Plaintiff obtained a judgment against Defendant from the Las Vegas Justice Court on June 14,
2014, awarding him $6,700. Plaintiff requests this Court grant him a declaratory judgment in the
amount of $46,900, attributing the increase from his original judgment to compensatory and punitive
damages. However, res judicata precludes this Court from creating a second judgment based on
claims already adjudicated by the Las Vegas Justice Court.1
“To take such a step would constitute a
denial of that full faith and credit which a federal court should give to the acts of a state court.”
Huron Holding Corp. v. Lincoln Mine Operating Co., 312 U.S. 183, 194 (1941).
B. Plaintiff’s Petition Does Not Meet Declaratory Judgment Requirements
Regardless of procedural bars, Plaintiff’s petition for a declaratory judgment is without merit,
as it does not meet the requirements of 28 U.S.C.A. § 2201.
1. Amount in Controversy
The amount in controversy required for the Court to issue a declaratory judgment is
$50,000. See 28 U.S.C.A. § 2201. The total judgment Plaintiff wishes to enforce is only $6,700.
Even accepting Plaintiff’s unsupported claim to seven times the original judgment only brings his
requested total to $46,900, which falls below the amount required by the statute.
2. Specific Language of Statute
28 U.S.C.A. § 2201(a) states, “In a case of actual controversy within its jurisdiction . .
. any court of the United States, upon the filing of an appropriate pleading, may declare the rights and
1
Plaintiff’s inability to enforce his judgment in this Court does not bar enforcement through proper means
other legal relations of any interested party seeking such declaration, whether or not further relief is
or could be sought.” Here, there is no actual controversy in existence, as the Las Vegas Justice Court
has already issued a judgment on all of Plaintiff’s claims. Further, Plaintiff does not seek a
declaration of his rights or legal relations, but rather seeks enforcement of a previously declared
judgment– an action distinct from what the specific language of § 2201(a) provides. As analyzed
supra, this Court has no authority to enforce Plaintiff’s state court judgment.
