Chick Kam Choo v. Exxon Corp.

486 U. S. 140

May 16, 1988

When a Singapore citizen was killed on a Exxon tanker, his wife filed a maritime case in a Federal District Court in Exxon’s home state of Texas. The District Court said that it was the improper forum because the case was far more connected to Singapore than America. The widow filed again in Texas state court, but Exxon got the District Court to issue an injunction against the state court considering the issue, due to the District Court’s previous improper forum ruling. The widow said that this injunction against the state court violated the Anti-Injunction Act.

Unanimously, the Supreme Court agreed. O’Connor said that the Anti-Injunction Act allowed injunctions to prevent issues resolved in federal courts from being re-litigated in state courts, but that this power should be narrowly construed. While the District Court ruled that the District Court itself was an improper forum, it did not specifically rule that Texas state courts were also improper forums (though, in a concurrence, Justice White said that the District Court certainly would have had the legal right to do so).  O’Connor pointed out that the District Court had resolved one legal claims that she was raising in the state court case. O’Connor did admit that the injunction was valid to the extent that it barred that specific legal claim from being re-litigated.

This was the right decision. If federal courts are going to start issuing injunctions against state court proceedings, they better have the most crystal clear of legal justifications for doing so.

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