Supreme Court of the United States
Toucey v. New York Life Insurance Co.
November 17, 1941314 U.S. 118
Summary
The Supreme Court reversed the lower courts, holding that a federal court may issue an injunction to stay state‑court proceedings that would relitigate issues already decided in the federal action, and that this power is not barred by 28 U.S.C. § 379 (formerly § 265) except for the bankruptcy exception.
Holding
- Whether § 379 bars a federal injunction staying state‑court relitigation of issues already decided in federal court.. No. The statutory prohibition does not apply to injunctions issued to protect and give effect to a federal decree, except where the injunction is authorized by bankruptcy law.
- Whether a federal court may enjoin state‑court proceedings to give effect to its decree.. Yes. A federal court may issue an injunction to prevent relitigation of issues already settled in its decree, and such injunctions are permissible under the statute.
Docket Nos. 16, 19
Cited authorities
- 36 Stat. 1162
- 28 U.S.C. § 379
- 1 Stat. 335
- 36 Stat. 1162
- 28 U.S.C. § 379
- 43 Harv. L. Rev. 345
- 42 Yale L.J. 1169
- 43 Harv. L. Rev. 345
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