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Civil Procedure – Anti-Injunction Act

By: WISCONSIN LAW JOURNAL STAFF//March 3, 2015//

Civil Procedure – Anti-Injunction Act

By: WISCONSIN LAW JOURNAL STAFF//March 3, 2015//

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U.S. Court of Appeals For the Seventh Circuit

Civil

Civil Procedure – Anti-Injunction Act

A district court may not enjoin class members from pursuing litigation in state courts.

“No one doubts that the district court has subject-matter jurisdiction over this litigation, and no one contends that trial or judgment in the Missouri litigation could imperil the district court’s ability and authority to adjudicate the federal suit. If the settlement collapses, the court’s adjudicatory competence remains. A need to adjudicate a suit on the merits after settlement negotiations fail does not undermine the nature or extent of a court’s jurisdiction. Yet if the Missouri case cannot diminish federal jurisdiction, §2283 precludes an injunction until the federal case reaches a final decision. (After a final decision, an injunction could be appropriate to protect the federal judgment, although class members who opt out would remain entitled to pursue their own suits.) Parallel state and federal litigation is common. The first to reach final decision can affect the other, either through rules of claim and issue preclusion (res judicata and collateral estoppel) or through effects such as reducing the scope of a class from 50 to 49 states. Yet the potential effect of one suit on the other does not justify an injunction.”

Reversed.

14-3436 Adkins v. Nestle Purina Petcare Co.

Appeal from the United States District Court for the Northern District of Illinois, Gettleman, J., Easterbrook, J.\

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