Hagan Eng’g, Inc. v. Mills, 115 Cal. App. 4th 1004 (2003)

Hagan Engineering, Inc., sued several of its former employees in state court, including Daniel G. Mills (collectively, “Mills”), for misappropriation of its trade secrets and related claims; Mills sued Hagan in federal court, alleging violations of ERISA. Eventually, the parties entered into a global settlement and dismissed both lawsuits with prejudice. Within two years, Hagan filed a motion in state court to enforce the settlement agreement pursuant to California Code of Civil Procedure Section 664.6; Mills opposed the motion on the ground that the court lacked jurisdiction since the underlying case had been dismissed with prejudice. Although the trial court granted Hagan’s motion to enforce the settlement agreement, the Court of Appeal reversed the judgment, holding that the dismissal of the lawsuit had deprived the trial court of subject matter jurisdiction.