Blog Post

Jun 16, 2011

SCOTUS Issues Ruling In Smith v. Bayer

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This morning the Supreme Court issued its long awaited and much anticipated ruling in Smith, et al. v. Bayer Corp., No. 09-1205 (U.S. June 16, 2011), on one of the key class action issues pending before the SCOTUS this term. The Smith case involves a situation where a federal court enjoined a state court from considering a plaintiff's request to certify a class action because the federal court had earlier denied a certification motion in a related case brought by a different plaintiff against the same defendant alleging similar claims. At issue was the federal court's order to enjoin the subsequent state court class action to prevent re-litigation of the class certification issue it had already decided and whether the federal court's order was consistent with the Anti-Injunction Act, 28 U.S.C. § 2283, which allows a federal court to enjoin a state court proceeding when necessary to "protect or effectuate [the federal court's] judgment."

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