Semtek International Inc. V. Lockheed Martin Corp.
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''Semtek v. Lockheed Martin'', 531 U.S. 497 (2001), is a
United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...
case in which the Court held that the claim preclusive effect of a federal judgment on a claim over which subject matter jurisdiction is based solely on
diversity Diversity, diversify, or diverse may refer to: Business *Diversity (business), the inclusion of people of different identities (ethnicity, gender, age) in the workforce *Diversity marketing, marketing communication targeting diverse customers * ...
is determined by the common law of the state in which the federal district court rendering the decision is located.


Background

Petitioners Semtek International Incorporated filed a complaint against Lockheed Martin in California state court, alleging a breach of contract. The case was removed to the local federal district court due to the diversity of citizenship in the case. The trial judge then dismissed the complaint, writing that California's 2-year statute of limitations made the claim "barred". Semtek International had also filed a claim in Maryland's state court. The court here also dismissed the complaint, but on the grounds that "the
res judicata ''Res judicata'' or ''res iudicata'', also known as claim preclusion, is the Latin term for ''judged matter'', and refers to either of two concepts in common law civil procedure: a case in which there has been a final judgment and that is no lon ...
effect" precludes this separate claim in a different state. Since another federal court had dismissed a similar action already, Semtek could not proceed in a different court on virtually similar contentions.


Opinion of the Court

Justice
Antonin Scalia Antonin Gregory Scalia (March 11, 1936 – February 13, 2016) was an American jurist who served as an associate justice of the Supreme Court of the United States from 1986 until his death in 2016. He was described as the intellectual an ...
wrote the unanimous decision of the Supreme Court, reversing the decision of the Maryland courts. Scalia wrote that there was no final "judgment on the merits" in the California case and thus the Maryland trial was not precluded. A reading of the appropriate rule could be seen as still permitting other actions. Therefore, Semtek was entitled to a trial before the Maryland courts and the case was remanded with such instructions.


See also

*
Erie Doctrine The ''Erie'' doctrine is a fundamental legal doctrine of civil procedure in the United States which mandates that a federal court called upon to resolve a dispute not directly implicating a federal question (most commonly when sitting in div ...
*
Jurisdiction Jurisdiction (from Latin 'law' and 'speech' or 'declaration') is the legal term for the legal authority granted to a legal entity to enact justice. In federations like the United States, the concept of jurisdiction applies at multiple level ...
*
U.S. Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...


References


External links

* United States Supreme Court cases 2001 in United States case law Lockheed Martin Diversity jurisdiction case law United States res judicata case law United States Supreme Court cases of the Rehnquist Court United States conflict of laws case law United States Erie Doctrine {{SCOTUS-Rehnquist-stub