The US Supreme Court [official website] on Thursday unanimously reversed [opinion, PDF] the lower court in Smith v. Bayer Corp. [Cornell LII backgrounder; JURIST report], allowing a class action lawsuit against the company to proceed. The Court held that under the re-litigation exception of the Anti-Injunction Act [28 USC § 2283], a district court exceeded its authority when it enjoined Smith from seeking class certification in state court after denying certification to a similar class. They also declared issues in the federal case and the state tribunal case different enough to warrant separate trials. Finally, the Court declared that the district court did not have personal jurisdiction over Smith, who was not a member of the initial class, and acted improperly when they denied him the ability to relitigate. Justice Elena Kagan delivered the opinion.
This case, indeed, is little more than a rerun of Chick Kam Choo. A federal court and a state court apply different law. That means they decide distinct questions. The federal court's resolution of one issue does not preclude the state court's determination of another. It then goes without saying that the federal court may not issue an injunction. The Anti-Injunction Act's re-litigation exception does not extend nearly so far.The opinion emphasized that there are few and narrow exceptions federal courts to enjoin state courts, and this, particularly, was not one of them.
In the case, Keith Smith filed a class action suit against Bayer [corporate website] in West Virginia state court due to claims arising out of Bayer's sale of an allegedly hazardous prescription drug called Baycol. However, George McCollins had previously sued Bayer in federal court seeking class action certification the month before. Eventually, McCollins' class did not receive certification. Due to this, Bayer argued that Smith's class claim, in state court, should also be denied certification under issue preclusion, and was granted an injunction on Smith's proceedings.