United States v. Stanley Warford, Robert Ellison, and Ina Ellison, Gerald L. Rainwaters and Cecil R. Howell

KRAVITCH, Circuit Judge:

The United States instituted this action, pursuant to 28 U.S.C. § 2410,1 to redeem property that had been purchased by Rain-waters and Howell. Both sides moved for summary judgment. The district court granted the United States’ motion and Rainwaters and Howell appealed. We must decide whether the United States’ suit is barred by res judicata.

I. BACKGROUND

This dispute involves property in Collier County, Florida. In February 1982, Robert and Ina Ellison filed an action in the Florida courts to foreclose a first mortgage. The Ellisons named the United States, a holder of…