## Facts

- Leong Chong, a Singapore resident, died in Singapore while performing repair work on a ship owned by Exxon-related entities.
- His widow, Chick Kam Choo, sued Exxon in the U.S. District Court for the Southern District of Texas under general federal maritime law, the Texas Wrongful Death Statute, and other federal and state causes of action.
- In 1980, the federal court granted summary judgment against the federal maritime claim, holding that choice-of-law principles required application of Singapore law rather than U.S. maritime law.
- The federal court dismissed the remaining claims on federal forum non conveniens grounds, conditioned on Exxon submitting to Singapore courts’ jurisdiction.
- Choo then filed a Texas state-court action asserting claims under Texas statutes and Singapore law; she voluntarily dismissed the federal claims from the state case.
- Exxon obtained a federal injunction barring Choo from prosecuting any claims relating to her husband’s death in Texas state court.
- The Fifth Circuit affirmed the injunction under the Anti-Injunction Act’s relitigation exception.

## Issues

1. Whether the Anti-Injunction Act’s relitigation exception (28 U.S.C. § 2283) permitted a federal injunction broadly barring state-court litigation after a prior federal judgment that (a) rejected a federal maritime-law claim on choice-of-law grounds and (b) dismissed the remaining federal case on forum non conveniens grounds.
2. Whether a federal forum non conveniens dismissal can preclude a state court from hearing related claims, including Singapore-law claims, where the state court may apply different forum non conveniens standards.

## Decision

- The Supreme Court held that the injunction was broader than necessary to “protect or effectuate” the 1980 federal judgment and therefore exceeded the relitigation exception’s limits.
- The Court ruled that the relitigation exception applies only to claims or issues actually decided by the prior federal judgment.
- The 1980 judgment did not decide the merits of Choo’s Singapore-law claims or whether Texas state court was an appropriate forum for them.
- The Court reversed in part and remanded for entry of a more narrowly tailored order, if any, limited to preventing relitigation of matters actually decided.

## Legal Principles

- The Anti-Injunction Act generally bars federal courts from enjoining state proceedings, subject only to specific, narrowly construed exceptions.
- Under the relitigation exception, a federal injunction may issue only when necessary to protect or effectuate a prior federal judgment, and only as to issues or claims actually decided in that judgment.
- Courts must determine the preclusive scope of the prior federal judgment by examining what the order actually resolved; a court may not expand the order’s effect based on what it was intended to accomplish.
- A federal dismissal on forum non conveniens grounds does not, by itself, determine whether a state court is an appropriate forum under state forum non conveniens doctrine.
- An injunction barring state litigation of claims not adjudicated in the prior federal action—such as unadjudicated Singapore-law claims—falls outside § 2283’s relitigation exception.

## Conclusion

The Court limited the Anti-Injunction Act’s relitigation exception to its preclusion function: federal courts may enjoin state proceedings only to prevent relitigation of matters actually decided in a prior federal judgment, and a prior federal forum non conveniens dismissal does not justify a blanket bar on related state-court claims.


Chick Kam Choo v. Exxon Corp., 486 U.S. 140 (1988)