Friday, December 6, 2013

Semtek Intl. Inc. v. Lockheed Martin Corp. case brief

Semtek Intl. Inc. v. Lockheed Martin Corp. case brief summary
531 U.S. 497 (2001)

Petitioner's claims against respondent were dismissed by the federal court as untimely under the forum state's law. Petitioner's action in the state court of a different forum, in which the claims were not untimely, was subsequently dismissed based on claim preclusion. Upon writ of certiorari, petitioner appealed the judgment of the Court of Special Appeals of Maryland, which affirmed the dismissal.

Petitioner's contract and business tort claims against respondent were dismissed on the merits by the federal court, sitting in diversity, on the ground that the statute of limitations of the court's forum state precluded the claims. Petitioner also asserted the same claims in the state court in a different forum, and the state court determined that the federal court dismissal was on the merits and thus was claim preclusive.

  • The United States Supreme Court held that the federal court's dismissal did not necessarily preclude the action in the alternate forum state. 
  • The dismissal on the merits, based on the statute of limitations, merely barred petitioner's remedy without extinguishing its substantive rights, and thus only precluded petitioner from pursuing the same claim in the dismissing court. 
  • Federal common law governed the effect of the dismissal by the federal court sitting in diversity, and such law required that the claim-preclusive effect of the federal judgment was governed by the law of claim preclusion of the federal court's forum state.

Judgment was reversed and remanded for further proceedings. The federal court's dismissal of petitioner's claims as untimely under forum state law, even though stated to be on the merits, did not necessarily preclude asserting the claims in a different forum state court. The preclusive effect of the dismissal in the diversity action was rather governed by the claim preclusion law of the federal court's forum state.

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