Toucey v. New York Life Insurance Co.

Summary

The Court held that § 265 of the Judicial Code does not forbid a federal court from enjoining state‑court proceedings to protect and give effect to its own decree, reversing the lower courts that had upheld such injunctions. The decision rests on a textual and historical analysis of the 1793 statute, rejecting the so‑called “relitigation” exception and emphasizing congressional intent to prevent federal interference in state courts except for limited statutory exceptions. Justice Reed’s dissent argues that the plain language of § 265 bars such injunctions and that the majority’s interpretation exceeds congressional intent.