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In re Diet Drugs Prods. Liab. Litig. - 282 F.3d 220 (3d Cir. 2002)

Rule:

That a state court may resolve an issue first, which may operate as res judicata, is not by itself a sufficient threat to the federal court's jurisdiction that justifies an injunction otherwise prohibited by the Anti-Injunction Act, 28 U.S.C.S. § 2283, unless the proceedings in state courts threaten to frustrate proceedings and disrupt the orderly resolution of the federal litigation. However, while the potentially preclusive effects of a State action may not themselves justify an injunction, they might do so indirectly. If the possibility of an earlier state court judgment is disruptive to settlement negotiations in an existing federal court action, the existence of the State court action might sufficiently interfere with the federal court's flexibility to justify an injunction. 

Facts:

In a complex class litigation concerning the sale and effects of appetite suppressants, the Texas sub-class' initial action was removed from a Texas State court and moved to federal court by American Home Products, and consolidated with the primary class action in the Eastern District of Pennsylvania. The parties reached a tentative settlement agreement for a nationwide class, and eventually the Pennsylvania district court entered a final order certifying the class and approving the settlement. The Texas sub-class moved to remand back to Texas state court during the opt out period; this motion was granted. But then they also attempted to opt out of the settlement as a group. The Pennsylvania District Court entered its orders enjoining the counsel and parties in the Texas sub-class from doing so. The Texas sub-class brought an interlocutory appeal, arguing that the order violated either the Rooker-Feldman doctrine or the Anti-Injunction Act, 28 U.S.C.S. § 2283

 

Issue:

In complex class litigation concerning the sale and effects of appetite suppressants, did a federal district court err in enjoining the counsel and parties in the Texas sub-class from attempting to opt out of the settlement as a group?

Answer:

No

Conclusion:

The United States Court of Appeals found that the Pennsylvania district court's injunction was necessary to protect its settlement of the nationwide class action, because the State action would seriously impair the federal court's ability to decide the case. The order of the district court entering the injunction was affirmed as an appropriate exercise of its authority.

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