The following excerpt is from Haphey v. Linn County, 924 F.2d 1512 (9th Cir. 1991):
4 While the general rule is that state law is determinative in the three categories of res judicata analysis outlined above, this rule is subject to the requirement that the first adjudication meet certain minimum federal standards. See generally, Gjellum v. City of Birmingham, 829 F.2d 1056, 1063-64 (11th Cir.1987) (reviewing federal standards).
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