Four requirements must be met to trigger the federal two-dismissal rule (FRCivP 41(a)(1)(B)): (1) the plaintiff voluntarily dismissed an action in either state or federal court, (2) thereafter the plaintiff voluntarily dismissed an action pending in federal court, (3) the two dismissals concerned the same claim, and (4) the plaintiff seeks to raise the twice-dismissed claim again in federal court. The majority opinion in this case holds that for purposes of determining whether the dismissals involved the “same claim,” the court should use the federal “same transaction” test used for federal res judicata purposes–i.e., if it arises from the same set of facts and the claim was or could have been raised in the prior action. A concurring opinion opts for using state res judicata rules regarding same claim at least for state law claims.