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In Rem and Res Judicata



"It is ancient law that a judgment in rem is res judicata as to all the world with regard to the res or status that is determined therein."


stating a judgment in rem "is not res judicata as to the facts or as to the subsidiary questions of law on which it is based, except as between parties to the proceeding or privies thereto," and observing "[t]he rule finds abundant illustration in cases dealing with decedents' estates and in cases involving the marriage status"

Brown v. Sojourner