California Supreme Court

Doe v. Marysville Joint Unified School Dist.

July 2, 2026

Summary

The court held that a second voluntary dismissal under the federal two-dismissal rule does not, by itself, preclude a later action on the same state-law claims in state court. The rule is a federal procedural bar that prevents refiling in the same federal court, not a rule of claim preclusion applicable in other courts, and the voluntary dismissal here was otherwise not a claim-preclusive judgment. The court reversed the Court of Appeal and remanded for further proceedings.