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Smith v. Bayer Corp. - 564 U.S. 299, 131 S. Ct. 2368 (2011)

Rule:

The Anti-Injunction Act, 28 U.S.C.S. § 2283, broadly commands that state court tribunals shall remain free from interference by federal courts. That edict is subject to only three specifically defined exceptions. And those exceptions, though designed for important purposes, are narrow and are not to be enlarged by loose statutory construction. Any doubts as to the propriety of a federal injunction against state court proceedings should be resolved in favor of permitting the state courts to proceed.

Facts:

Petitioner consumers sued respondent pharmaceutical company in the state court regarding a drug. Respondent moved in federal district court for an injunction ordering the state court not to consider the motion for class certification filed by the petitioners. The respondent had persuaded the same federal district court to deny a similar class-certification motion that had been filed against respondent by a different plaintiff. Thereafter, the federal district court enjoined the state court from hearing a certification motion under the relitigation exception to the Anti-Injunction Act, 28 U.S.C.S. § 2283. The appellate court affirmed. The Supreme Court of the United States granted certiorari.

Issue:

Could a federal district court enjoin a state court from hearing a certification motion under the relitigation exception to the Anti-Injunction Act, 28 U.S.C.S. § 2283 after denial of a certification in a similar suit?

Answer:

No.

Conclusion:

In enjoining the state court from considering Smith's class certification request, the federal district court exceeded its authority under the “relitigation exception” to the Anti-Injunction Act, 28 U.S.C.S. § 2283. The federal district court's rejection of the certification in the federal suit did not preclude a later adjudication in the state court of the consumer's class certification motion. The issue decided by the federal district court was not the same issue as the one presented in the state court because federal and state certification rules were not identical. In addition, the petitioner consumer was not a party to the federal suit, and he was not bound to the federal court ruling since the certification motion had been denied.

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