Semtek International, Inc. v. Lockheed Martin Corp

In Semtek International, Inc. v. Lockheed Martin Corp., 531 U.S. 497 (2001), the plaintiff, Semtek International, Inc. ("Semtek"), brought various contract and tort claims against the defendant, Lockheed Martin Corporation ("Lockheed"), in California state court. See id. at 499. The case was removed to federal court based on diversity of citizenship. See id. The U.S. District Court for the Central District of California then granted Lockheed's motion to dismiss on the grounds that all of Semtek's claims were barred by California's two-year statute of limitations. See id. The U.S. Court of Appeals for the Ninth Circuit affirmed. See id. Thereafter, Semtek filed an identical lawsuit against Lockheed in the Circuit Court for Baltimore City in order to take advantage of Maryland's three-year statute of limitations. See id. Ultimately, the circuit court granted Lockheed's motion to dismiss because, under federal preclusion law, the federal court's dismissal of Semtek's claims on statute of limitations grounds was a final judgment on the merits under the doctrine of res judicata. See id. at 500. The Court affirmed, holding that federal law established the preclusive effect of federal judgments in subsequent identical state court actions, and as a result, the prior dismissal of Semtek's claims by a federal court on statute of limitations grounds was a judgment on the merits for res judicata purposes, thereby precluding litigation of those claims in Maryland. See id. Although the Court of Appeals declined to review our opinion, the U.S. Supreme Court granted certiorari and reversed and remanded. See Semtek, 531 U.S. at 500. The Supreme Court held that the claim-preclusive effect of a federal court's dismissal on state statute of limitations grounds in a diversity action is governed by a federal rule that incorporates the claim-preclusion law applied by the state courts in the state in which the federal court sits. See id. at 509.