United States Second Circuit

Following the approval of a federal class action settlement, the District Court's judgment enjoining a state court action for legal malpractice directed at counsel for the plaintiff class is affirmed where: 1) the "in aid of jurisdiction" exception to the Anti-Injunction Act cannot form the basis for the injunction of the state court action, because the limited circumstances in which the injunction of an in personam action may be appropriate "in aid of" the court’s jurisdiction are not present in this case; but 2) the injunction of the state court action was proper under the "relitigation" exception to the Anti-Injunction Act, since the award of attorneys' fees in the class action precludes a subsequent malpractice action where, as here, the parties had a full and fair opportunity to litigate the reasonableness of counsel's representation.

Appellate Information

• Decided 10/10/2012
• Published 10/10/2012

Judges

• CABRANES

Court

• United States Second Circuit

Counsel