Supreme Court Decision Alert - June 16, 2011

Originally published June 16, 2011

Keywords: class actions, federal class certification rulings, Anti-Injunction Act, relitigation exception, multidistrict litigation

Today the Supreme Court issued one decision, described below, of interest to the business community.

Class Actions—Preclusive Effect of Federal Class Certification Rulings

Smith v. Bayer Corp., No. 09-1205 (previously discussed in the September 28, 2010 Docket Report).

The federal Anti-Injunction Act generally bars federal courts from enjoining proceedings in state court. 28 U.S.C. § 2283. One exception to that prohibition, commonly known as the "relitigation exception," permits a federal court to enjoin state court litigation "to protect or effectuate [the federal court's] judgments." In Smith v. Bayer Corp., a federal court presiding over multidistrict litigation against Bayer applied that exception, enjoining class certification proceedings that were pending in West Virginia state court