Ex Parte Skinner & Eddy Corp.

Background

A Washington shipbuilding company sued the United States in the Court of Claims for over $17 million, mainly over canceled contracts, extra work, and anticipated profits. After the government did not promptly file an answer or a counterclaim, the company moved to dismiss its federal case without prejudice. The Court of Claims dismissed the suit, and the next day the company filed a similar suit in a Washington state court for about $9.1 million, omitting some claimed anticipated profits. Months later the federal court vacated its dismissal and allowed the government to file a counterclaim.

Reasoning

The Court considered whether a plaintiff can voluntarily dismiss a pending claim and whether the Court of Claims could later reopen the case. Relying on long-standing common-law practice, the Court reaffirmed a plaintiff’s broad right to dismiss before final judgment. It found the government had not taken steps that would make dismissal unfair or prejudicial, since no counterclaim had been prepared when the suit was dismissed. The Court also applied a statute that bars federal claims courts from hearing claims when a similar suit has been filed in another court; because the company promptly filed in state court, the federal court could not regain jurisdiction over those claims. For these reasons the high court granted an extraordinary order (mandamus) directing the Court of Claims to restore its dismissal and forbidding further action.

Real world impact

The decision enforces a plaintiff’s ability to dismiss a federal claim and then pursue related claims in state court without the federal claims court later reclaiming them. It protects a party’s access to a state jury trial and stops the federal court from wasting time on a case the plaintiff has chosen to pursue elsewhere.