ORLONZO HEDRINGTON, ET AL V. USA
Split Score
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Case Summary
Disposition
Reversed
The Ninth Circuit held that the district court erred in giving claim-preclusive effect to a time-barred FTCA action (Hedrington II) to dismiss an earlier, timely FTCA suit (Hedrington I). Relying on its precedent in Filice, the court ruled that California’s claim-preclusion law governs because the alleged tort occurred in California, reversed the grant of summary judgment to the United States, and remanded for further proceedings.
Circuit Split Identified
Legal Issue
Whether, in Federal Tort Claims Act cases, the claim-preclusive effect of a prior federal judgment is governed by the forum State’s law where the act or omission occurred or by federal common-law res judicata principles.
Circuit Positions
State claim-preclusion law governs FTCA judgments (apply law of the State where the act or omission occurred).
Federal common-law res judicata governs the preclusive effect of FTCA judgments (state rules are not incorporated).
Conflict Summary
The Ninth Circuit holds that the FTCA’s directive to apply the “whole law of the State where the act or omission occurred” incorporates that State’s claim-preclusion rules, while the Fifth Circuit applies federal claim-preclusion principles, treating a prior federal judgment (including statute-of-limitations dismissals) as preclusive regardless of state rules.