When a state court dismisses a complaint as in conflict 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 prosecuting 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 complaint 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.

Whether a state court must explain why a plaintiff should have previously raised a state law issue under the entire controversy doctrine