Mortgagelinq Corporation and Federal Home Loan Mortgage Corporation, Plaintiffs-Appellants v. Commonwealth Land…

Summary

The Supreme Court of New Jersey held that the entire controversy doctrine bars a New Jersey action against parties that could have been joined in an earlier federal suit in Pennsylvania where jurisdiction existed, and that dismissals under the doctrine should be without prejudice. The Court affirmed the lower court’s application of the doctrine but reversed the dismissal with prejudice. The decision also clarifies that the doctrine does not have extraterritorial effect beyond New Jersey.