Semtek Intl Inc v Lockheed Martin Corp

2001

Venue: SCOTUS

Facts: No idea. Breach of contract, business torts..

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.

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?

Holding: No. Reversed.

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.

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'.

Dicta: