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Civil Procedure Keyed to Yeazell
Matsushita Elec. Industrial Co. v. Epstein
Facts
The Defendant was the subject of two sets of lawsuits filed on behalf of MCA shareholders after Defendant acquired MCA. Both suits consisted primarily of class actions. One group of class actions alleged breach of federal securities laws. The second, filed in Delaware State Court, alleged breaches of various state law fiduciary responsibilities. The claims in the federal actions all fell within the federal courts’ exclusive jurisdiction. After the federal district court granted summary judgment to Defendant in the federal cases, but while those cases were on appeal to the Court of Appeals for the Ninth Circuit, the parties to the Delaware action negotiated a global release of all claims arising out of the Matsushita-MCA acquisition. The Delaware court approved the settlement as fair. Later, Defendant asserted the judgment embodying the settlement as a bar to the federal action. The Ninth Circuit, before which the federal securities claims were pending, held that adjudication of the state claims could have had no preclusive effect on issues on the federal case. The Supreme Court of the United States (Supreme Court) then granted certiorari.
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