Syngenta Crop Prot., Inc. v. Henson - 537 U.S. 28, 123 S. Ct. 366 (2002)

Rule:

Where a statute specifically addresses the particular issue at hand, it is that authority, and not the All Writs Act, that is controlling. The right of removal is entirely a creature of statute and a suit commenced in a state court must remain there until cause is shown for its transfer under some act of Congress. These statutory procedures for removal are to be strictly construed. Petitioners may not, by resorting to the All Writs Act, avoid complying with the statutory requirements for removal.

Facts:

Respondent in a Louisiana state court, an action which asserted various tort claims related to the petitioners' manufacture and sale of an insecticide. The state court stayed the respondent’s action when he successfully intervened in a similar action that was already underway in the United States District Court for the Southern District of Alabama and participated in an ensuing settlement which the District Court approved, and over which settlement the District Court assertedly retained jurisdiction. After the settlement, and apparently contrary to the settlement's terms, the respondent's counsel told the state court that the settlement required dismissal of only some of the state-court claims. The petitioners then removed the action to the United States District Court for the Middle District of Louisiana, on the two asserted bases of the All Writs Act, and ancillary jurisdiction under the supplemental-jurisdiction statute (28 USCS 1367). This District Court transferred the former state-court action to the District Court in Alabama, which dismissed the action as allegedly barred by the settlement in question. On appeal, the United States Court of Appeals for the Eleventh Circuit, in vacating the dismissal and in ordering a remand in pertinent part, expressed the view that the All Writs Act could not properly support removal of the state-court action. The United States Supreme Court granted certiorari.

Issue:

Could the All Writs Act properly support removal of the respondent’s state-court action? 

Answer:

No.

Conclusion:

The Supreme Court affirmed the decision of the appellate court, holding that the All Writs Act, alone or in combination with the existence of ancillary jurisdiction in a federal court, was not a substitute for the requirement of 28 USCS 1441(a) that a federal court must have original jurisdiction over an action in order for the action to be removed from a state court. Thus, the removal of the state-court action in question was not authorized under the two bases asserted by the petitioners – even though the petitioners alleged that such removal was necessary to prevent the frustration of the terms of the federal-court settlement--where neither the All Writs Act nor ancillary jurisdiction provided federal courts with the original jurisdiction required by 1441(a).