Supreme Court of the United States
Smith v. Bayer Corp.
June 16, 2011564 U.S. 299
Summary
The Court held that the federal district court exceeded its authority under the Anti-Injunction Act by enjoining a state court from considering certification of a similar class action. The relitigation exception did not apply because the federal and state courts were applying materially different class-certification standards, and the state plaintiff was not a party or otherwise bound by the federal judgment. The Court therefore reversed the Court of Appeals.
Holding
- Same issue under the relitigation exception. The federal court's denial of certification did not preclude the state court from considering Smith's certification motion because the federal and state courts applied materially different legal standards.
- Binding effect on a nonparty. Smith was not bound by the federal judgment because she was neither a party to the federal action nor a member of a certified class.
- Authority to issue the injunction. The injunction was unauthorized because the Anti-Injunction Act's relitigation exception permits an injunction only when the former federal adjudication clearly precludes the state court's decision.
Docket 09-1205
Cited authorities
- West Virginia Rule of Civil Procedure 23
- 28 U.S.C. § 1441
- Rule 23
- Rule 23(b)(3)
- 28 U.S.C. §§ 1332
- 28 U.S.C. §§ 1332
- 28 U.S.C. §2283
- 28 U.S.C. §§ 1332