Cases by Issue - Collateral Estoppel

Semtek v. Lockheed Martin

Mon, 05 Jan 2009 17:44:27 +0000

Case Basics

Docket No.

99-1551

Petitioner

Semtek

Petitioner Type

Petitioner

Respondent

Lockheed Martin

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 497 (2001)

Argued

Tuesday, December 5, 2000

Decided

Tuesday, February 27, 2001

Advocates

Walter E. Dellinger, III (Argued the cause for the respondent)

Michael H. Gottesman (Argued the cause for the petitioner)

Facts of the Case

Semtek International filed a complaint against Lockheed Martin Corporation in California state court, alleging breach of contract and various business torts. Based on diversity of citizenship, Lockheed Martin moved the case to the District Court. In the District Court, Lockheed Martin successfully moved to dismiss Semtek's claims, as they were barred by California's 2-year statute of limitations. The dismissal was upheld on appeal. Semtek then filed suit in the State Circuit Court for Baltimore City, Maryland, alleging the same causes of action. The suit was not time barred under Maryland's 3-year statute of limitations. The court dismissed the case under res judicata. In affirming, the Maryland Court of Special Appeals held that the California federal court's dismissal barred the Maryland complaint because the res judicata effect of federal diversity judgments is prescribed by federal law, under which the earlier dismissal was on the merits and claim-preclusive.

Question

Is the claim-preclusive effect of a federal judgment dismissing a diversity action on statute-of-limitations grounds determined by the law of the state in which the federal court sits?

Conclusion

Decision: 9 votes for Semtek, 0 vote(s) against
Legal provision: Federal Rules of Civil Procedure, including Appellate Procedure (or relevant rules of a circuit court)

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that "[b]ecause the claim-preclusive effect of a federal court's dismissal 'upon the merits' of a diversity action on state statute-of-limitations grounds is governed by a federal rule, which in turn (in diversity cases) incorporates the claim-preclusion law that would be applied by state courts in the State in which the federal court sits, the Maryland Court of Special Appeals erred in holding that the California federal court's dismissal 'upon the merits' necessarily precluded the Maryland state-court action." Thus, the District Court's dismissal on the merits of claims as untimely under California law did not preclude Semtek from asserting its claims in a different state court forum.

United States v. Stauffer Chemical Co.

Mon, 05 Jan 2009 17:29:35 +0000

Case Basics

Docket No.

82-1448

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Stauffer Chemical Co.

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

464 U.S. 165 (1984)

Argued

Wednesday, November 2, 1983

Decided

Tuesday, January 10, 1984

Advocates

Louis F. Claiborne (on behalf of Petitioner)

Charles F. Lettow (on behalf of Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Stauffer Chemical Co., 0 vote(s) against
Legal provision: Estoppel

None

United States v. Mendoza

Mon, 05 Jan 2009 17:29:21 +0000

Case Basics

Docket No.

82-849

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Mendoza

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

464 U.S. 154 (1984)

Argued

Wednesday, November 2, 1983

Decided

Tuesday, January 10, 1984

Advocates

Donald L. Ungar (on behalf of Respondent)

Kenneth S. Geller (on behalf of Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Estoppel

None

Federated Department Stores, Inc. v. Moitie

Mon, 05 Jan 2009 17:28:55 +0000

Case Basics

Docket No.

79-1517

Petitioner

Federated Department Stores, Inc.

Petitioner Type

Petitioner

Respondent

Moitie

Respondent Type

Respondent

Heard By

Burger Court (1975-1981)

Decided By

Burger Court (1975-1981)

Opinion

452 U.S. 394 (1981)

Argued

Monday, March 30, 1981

Decided

Monday, June 15, 1981

Advocates

Jerome I. Chapman (on behalf of the Petitioners)

Jerrold N. Offstein (on behalf of the Respondents)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Federated Department Stores, Inc., 1 vote(s) against
Legal provision: res judicata

None

Ford v. Ford

Mon, 05 Jan 2009 17:38:21 +0000

Case Basics

Docket No.

Petitioner

Ford

Petitioner Type

Petitioner

Respondent

Ford

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

371 U.S. 187 (1962)

Argued

Thursday, November 15, 1962

Decided

Monday, December 10, 1962

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Ford, 0 vote(s) against
Legal provision: Article 4, Section 1: Full Faith and Credit Clause

None

Lance v. Dennis

Mon, 05 Jan 2009 17:45:11 +0000

Case Basics

Docket No.

05-555

Appellee

Dennis

Petitioner Type

Appellee

Appellant

Lance

Respondent Type

Appellant

Decided By

Roberts Court (2006-2009)

Opinion

546 U.S. ___ (2006)

Decided

Tuesday, February 21, 2006

Facts of the Case

When the Colorado legislature failed to pass a redistricting plan in 2000, the state courts created one at the request of a group of voters. The legislature succeeded in passing a redistricting plan in 2003. The state attorney general brought suit in the Colorado State Supreme Court to require the secretary of state to use the court-ordered plan, and the Colorado General Assembly defended its own plan. The Colorado Supreme Court ruled that the legislature's plan violated Article V of the State Constitution. A group of citizens including Keith Lance brought another suit in federal court alleging that Article V of the Colorado Constitution, as interpreted by the Colorado Supreme Court, violated the Elections Clause of the U.S. Constitution. Under the Supreme Court's Rooker-Feldman doctrine, no federal court except the Supreme Court may hear appeals from state courts. The District Court held that since Lance was in privity with the General Assembly - that is, their claims were similar enough to constitute a mutual interest - Lance's suit was in effect an appeal of the General Assembly's loss in state court. Therefore, the District Court ruled that it had no jurisdiction under the Rooker-Feldman doctrine and declined to hear the case.

Question

Does the Rooker-Feldman doctrine preclude plaintiffs from bringing suit in federal court when they are in privity with a party that lost in state court?

Conclusion

Decision: 9 votes for Lance, 0 vote(s) against
Legal provision:

No. In an anonymous 8-1 decision, the Court reversed the District Court. The Court held that "The Rooker-Feldman doctrine does not bar actions by nonparties to the earlier state-court judgment simply because [...] they could be considered in privity with a party to the judgment." Since Lance was not a party to the state-court suit, and was in no position to appeal the Colorado Supreme Court's decision, the District Court had jurisdiction to hear the case. Justice John Paul Stevens wrote a lone dissent expressing a desire to address the validity of the claims brought by Lance's suit.