Semtek Int'l Inc. v. Lockheed Martin Corp

In Semtek Int'l Inc. v. Lockheed Martin Corp. (2001) 531 U.S. 497, a California federal court in a diversity case dismissed a complaint on statute-of-limitations grounds. The plaintiff then filed the same action in Maryland state court, where a longer limitations period had not yet expired. The Maryland court dismissed the second action on claim-preclusion grounds, reasoning that federal law governed the preclusive effect of the first dismissal, and that the first dismissal on limitations grounds would be considered a judgment on the merits under federal common law governing claim preclusion. In reversing, the Supreme Court framed the issue before it as follows: "This case presents the question whether the claim-preclusive effect of a federal judgment dismissing a diversity action on statute-of-limitations grounds is determined by the law of the State in which the federal court sits." (Semtek, supra, 531 U.S. at p. 499.) It then confirmed that, not only is the claim-preclusive effect of a federal diversity judgment a question of federal law, but further stated that the claim-preclusive effect of all federal judgments is a question of federal law ultimately decided by the Supreme Court. It continued, however, by stating that the best federal rule for the claim-preclusive effect of a federal diversity judgment is to adopt "the law that would be applied by state courts in the State in which the federal diversity court sits." (Id. at p. 508.) It remanded and directed the Maryland court to apply California claim preclusion law to determine the res judicata effect of the California federal court decision.