Donovan v. City of Dallas

Summary

Justice Black's majority opinion held that state courts cannot restrain parties from prosecuting an in personam action in federal courts having jurisdiction over the parties and subject matter. Any res judicata defense must be decided by the federal court, and directing an injunction at the litigants rather than the federal court does not avoid this rule. The Court reversed the Texas Supreme Court's judgment directing issuance of the injunction and vacated the resulting contempt judgment, remanding without deciding whether contempt punishment could rest on disobedience of an invalid order. Justice Harlan, joined by Justices Clark and Stewart, dissented, arguing that state courts retain equitable power to prevent resident litigants from pursuing vexatious federal litigation that frustrates an existing state judgment; he would have affirmed.