In the 1983 case of Migra v. Warren City School District Board of Education, Estelle Migra sued the school district in Ohio state court for breach of contract and violation of her First Amendment rights after she was fired from her teaching position. After receiving a partial judgment in state court, she then filed suit in federal court under Section 1983 for civil rights violations based on the same facts as those presented to the state court. The U.S Supreme Court ruled against Migra, holding that when a plaintiff brings a §1983 claim in federal court following litigation of related claims in state courts, they are bound by principles known as res judicata (claim preclusion) or collateral estoppel (issue preclusion). Essentially this means that once an issue has been decided by a competent court it cannot be relitigated again even if brought under different legal theories or claims. This decision affirmed that these principles apply equally to both federal and state courts.

In the dissenting opinion for Migra v. Warren City School District Board of Education, Justice Brennan argued that federal courts should not be barred from hearing a Section 1983 claim simply because a state court has already decided on an identical issue under state law. He contended that this decision undermines the purpose of Section 1983 as it was intended to provide a federal remedy distinct from any available at the state level. Furthermore, he noted that Congress did not intend for prior litigation in state court to preclude subsequent litigation in federal court when it enacted Section 1983 and its jurisdictional counterpart, 28 U.S.C §1343(3). Therefore, according to Justice Brennan's dissenting view, Ms. Migra should have been allowed to pursue her claims against Warren City School District Board of Education et al., despite having previously litigated similar issues before Ohio’s courts.