holding that the “Anti-Injunction Act does not bar courts with jurisdiction over complex multidistrict litigation from issuing injunctions to protect the integrity of their rulings . . . as long as the injunctions are narrowly crafted to prevent specific abuses which threaten the court's ability to manage the litigation effectively and responsibly”
How later courts described this case
- holding that the “Anti-Injunction Act does not bar courts with jurisdiction over complex multidistrict litigation from issuing injunctions to protect the integrity of their rulings . . . as long as the injunctions are narrowly crafted to prevent specific abuses which threaten the court's ability to manage the litigation effectively and responsibly”
- holding that, where “state and federal courts had concurrent jurisdiction” over a dispute involving the legality of picketing by a union, “neither court was free to prevent either party from simultaneously pursuing claims in both courts”
- holding that the Anti- Injunction Act did not permit injunction of state court foreclosure proceeding
- concluding that a prior federal court order focused only on the application of federal law and therefore could not justify an injunction of a contradictory state court order where the state court had ruled as a matter of state law
Written by the judges who cited it.
Later courts went against this
Declined to follow by United States v. Schurkman, 728 F.3d 129 (2013)
398 U.S. at 287, 90 S.Ct. 1739, we decline to extend the holding of
Distinguished
Distinguished by In Re BankAmerica Corp. Securities Litigation, 95 F. Supp. 2d 1044 (2000)
Because the applicability of one exception is all that is needed to authorize an injunction under the Act, Atlantic Coast Line R.R., 398 U.S. at 286-87, 90 S.Ct. 1739, Skywalk and National Basketball Ass'n are inapplicable to the Court's decision in this case.
The opinion
Mr. Justice Harlan,
concurring.
I join the Court’s opinion on the understanding that its holding implies no retreat from Brotherhood of Railroad Trainmen v. Jacksonville Terminal Co., 394 U. S. 369 (1969). Whether or not that case controls the underlying controversy here is a question that will arise only on review of any final judgment entered in the state court proceedings respecting that controversy.