Venue: |
SCOTUS
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Facts: |
No idea. Breach of contract, business torts.. |
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Posture: |
Semtek sues in CA state court. Lockheed removes to federal court,
gets the thing dismissed under the CA 2-year statute of limitations.
Semtek next sues in MD state court, where the SOL is 3 years.
MD state court grants dismissal as res judicata. Court
of Special Appeals affirms. |
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Issue: |
Is the claim-preclusive effect of a federal judgment dismissing an
action for statute of limitations grounds determined by the law
of the state where the federal court sits? |
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Holding: |
No. Reversed. |
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Rule: |
The dismissal in the CA court barred refiling in the same court,
but a dismissal in one forum isn't claim-preclusive in a
forum with different rules. |
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Reasoning: |
State, rather than federal law is at issue here, so there is no
strong need for uniformity. We don't want one state's statute
of limitations to act as a bar against others'. There's no
federal interest in privileging one state's statute of limitation
over others'. |
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Dicta: |
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