United States Second Circuit

The district court's order enjoining defendant pursuant to the Anti-Injunction Act from litigating in any court other than the Southern District of New York issues related to a consent decree that resolved an environmental enforcement action brought against defendant by the government under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 and the Fair Debt Collection Practices Act of 1990 is vacated and remanded, where: 1) under the circumstances the statutory exception to the Anti-Injunction Act which permits a federal court to enjoin state proceedings "where necessary in aid of its jurisdiction" does not apply; and therefore, 2) the Anti-Injunction Act's general prohibition against a federal injunction of state proceedings precludes the district court from enjoining defendant's state suit.

Appellate Information

• Decided 08/27/2013
• Published 08/27/2013

Judges

• HALL

Court

• United States Second Circuit

Counsel