Adams v. Pacific Bell Directory

In Adams v. Pacific Bell Directory (2003) 111 Cal.App.4th 93, the Court held that a prior Ninth Circuit decision in the case established the law of the case. (Id. at p. 97.) The Ninth Circuit had ruled federal law did not preempt the plaintiffs' state law claims and remanded the case to state court, but the state court responded by holding federal law did preempt the claims and granted the defendant summary judgment. (Id. at p. 95.) This resulted in "the incongruous conclusion that neither the federal nor the state court had jurisdiction to decide the controversy." (Ibid.) The Court therefore held the federal decision was the law of the case so as to provide "the parties with a forum to litigate their dispute." (Id. at p. 97.) But we also stated: "To allow the trial court to revisit the Ninth Circuit's ruling would contravene the policies underlying the law of the case doctrine -- conservation of judicial resources and ensuring the finality of decisions." (Id. at p. 98.)