New Jersey’s entire controversy doctrine — which requires all claims stemming from the same event to be litigated in one lawsuit — should not be applied by a federal court sitting in New Jersey to bar a suit where all of the prior litigation was also federal, the 3rd U.S. Circuit Court of Appeals has ruled.
“Federal courts should apply the general rule that the preclusive effect of a judgment is determined by the preclusion law of the issuing court — in this case, a federal court,” Chief U.S. Circuit Judge Edward R. Becker wrote in Paramount Aviation Corp. v. Gruppo Agusta.
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