Cornus Corp. v. GEAC Enterprise Solutions, Inc.

The claim preclusive effect of a federal court's judgment is governed by Oregon's claim preclusion law, which states that a claim brought in federal court is not barred in state court unless it was adjudicated on the merits.

Cornus Corp. appealed a dismissal by the circuit court in which it ruled that the doctrine of claim preclusion barred the court from hearing the case. In 2004, Cornus Corp. filed a breach of contract claim against GEAC Enterprise Solutions, Inc. and AMSI (GEAC) in federal district court. The case was originally dismissed because Cornus Corp. failed to respond to an order to show cause. After two failed attempts at filing for relief, Cornus Corp. filed a complaint in Jackson County Circuit Court. GEAC moved for summary judgment based on claim preclusion. GEAC argued that since the current case involved the same factual claims and parties as the action that was dismissed by the district court, the new case in circuit court was precluded from being tried. The circuit court granted the GEAC's motion. The Court of Appeals held that Oregon’s claim preclusion law governs the claim preclusive effect of a federal judgment, and there was no adjudication on the merits before dismissal in federal court. Reversed and remanded.