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Conflict of Laws Keyed to Brilmayer
Semtek Intl. Inc. v. Lockheed Martin Corp.
Citation:
531 U.S. 497 (2001)Facts
Plaintiff, Semtek Intl. Inc., filed a complaint against Defendant, Lockheed Martin Corp., in California state court, alleging breach of contract and various torts. Lockheed moved the case to the U.S. District Court for the Central District of California on the basis of diversity of citizenship. The district court granted Lockheed’s motion to dismiss Semtek’s claims, finding that the claims were barred by California’s two-year statute of limitations. The district adopted Lockheed’s proposed language, dismissing Semtek’s claims “in their entirety on the merits and with prejudice.” Semtek appealed to the Court of Appeals for the Ninth Circuit, but did not contest the district court’s designation of its dismissal as “on the merits.” The Ninth Circuit affirmed the district court’s order.
Semtek then brought suit against Lockheed in the State Circuit Court for Baltimore City, Maryland, alleging the same causes of action. The claims were not time barred under Maryland’s three-year statute of limitations. Lockheed sought injunctive relief against the Maryland action from the California federal court, and removed the action the the U.S. District Court for the District of Maryland on federal-question grounds. The California federal court denied the requested relief, and the Maryland federal court remanded the case to state court. The Maryland state court then granted Lockheed’s motion to dismiss on the grounds of res judicata. Semtek returned to the California federal court, and moved to amend the district court’s earlier order to indicate that the dismissal was not on the merits. The motion was denied. Semtek also appealed the Maryland trial court’s order of dismissal to the Maryland Court of Special Appeals. The Court of Special Appeals affirmed. After the Maryland Court of Appeals declined to review the case, the U.S. Supreme Court granted certiorari.
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Choice of Law