holding that the Anti-Injunction Act prohibits federal courts from enjoining state court proceedings unless (1) expressly authorized by Act of Congress; (2) where necessary in aid of its jurisdiction; or (3) to protect or effectuate its judgments
How later courts described this case
- holding that the Anti-Injunction Act prohibits federal courts from enjoining state court proceedings unless (1) expressly authorized by Act of Congress; (2) where necessary in aid of its jurisdiction; or (3) to protect or effectuate its judgments
- explaining that the relitigation exception only applies when “the claims or issues which the federal injunction insulates from litigation in state proceedings actually have been decided by the federal court”
- stating that the purpose of the Act is to forestal “the inevitable friction between the state and federal courts that ensues from the injunction of state judicial proceedings by a federal court”
- stating that the relitigation exception is “designed to permit a federal court to prevent state litigation of an issue that previously was presented to and decided by the federal court”
Written by the judges who cited it.
Distinguished
Distinguished by Fletamentos Maritimos, S.A. v. Maritima Albatros, S.A., 944 F. Supp. 906 (1996)
Chick Kam Choo is distinguishable, they say, because there the Texas courts applied a different forum non conveniens doctrine than the federal courts.
The opinion
Justice White,
concurring.
I agree with the Court that, as a general matter, “[fjederal forum non conveniens principles simply cannot determine whether [state] courts, which operate under a broad ‘open-courts’ mandate, [will] consider themselves an appropriate forum” for a federal litigant’s lawsuit. Ante, at 148. Consequently, in diversity cases — for example — a district court’s dismissal on forum non conveniens grounds cannot serve as a basis for a later injunction if the plaintiff subsequently brings the same action in a state court.
But, as the Court recognizes, this case involves the special area of federal maritime law. Ante, at 149. In,this field, the federal interest in uniformity is so substantial that a determination that federal law requires that a case be heard in a foreign forum could possibly pre-empt any contrary determination by a state court applying state forum non con-veniens law. The Court acknowledges that our precedents may ultimately support such a conclusion in this case. Ante, at 149-150.
Had the District Court made such a finding here when it dismissed petitioner’s case — holding that federal maritime law required-that this case be heard in Singapore — then I be *152 lieve that the relitigation exception found in 28 U. S. C. §2283 would permit the injunction that the District Court later issued. Contra, Zipfel v. Halliburton Co., 832 F. 2d 1477, 1488 (CA9 1988), cert. pending sub nom. Crowley Maritime Corp. v. Zipfel , No. 87-1122. This is true whether or not a finding of such pre-emption would have been correct: petitioner’s remedy for an erroneous pre-emption decision would have been an appeal of the District Court’s dismissal, and not relitigation of the issue in state court. However, the District Court’s terse dismissal order in this case lacks any express ruling on uniformity or pre-emption. See App. 34-35. Absent such a holding, the District Court had no “judgment” on this question which it needed to “protect or effectuate” by enjoining the subsequent state court litigation. Cf. 28 U. S. C. §2283 .
Consequently, I agree with the Court that the relitigation exception to § 2283 cannot be invoked here, ante, at 150, and the judgment of the Court of Appeals affirming the District Court’s injunction must be reversed in pertinent part.