Robert William Moss v. Shawn M. Latourette, Commissioner, New Jersey Department of Environmental Protection

When a state court dismisses a complaint as in con­ flict with the entire controversy doctrine, on the ground that it raises a question of state law of which the plaintiff should have been aware when prosecut­ ing a previous complaint, must the court explain why the plaintiff should have previously been aware? Three questions are involved: • the underlying question of state law, the nature of which is immaterial; • a procedural question of state law, viz. whether the state court correctly concluded that the com­ plaint offended the entire controversy doctrine on the ground stated; and • a federal question, arising upon completion of the state court litigation: whether the plaintiffs 14th Amendment right to Due Process while being heard was abridged.