## Facts

- Nationwide products-liability claims alleged defective fuel system design in certain General Motors pickup trucks created heightened fire risk in side-impact collisions.
- A federal multidistrict litigation (MDL) in the Eastern District of Pennsylvania previously attempted a nationwide settlement class; the Third Circuit vacated that certification and settlement and remanded for further proceedings.
- After the remand, some plaintiffs pursued a restructured settlement in a Louisiana state-court class action involving substantially the same alleged defect.
- Objecting truck owners/class members sought an emergency injunction in the federal MDL court to stop the Louisiana settlement proceedings.
- The federal district court denied the request to enjoin the state-court action.
- While the appeal of that denial was pending, the Louisiana court entered final judgment approving the settlement (after delaying entry while the federal court considered the injunction request).

## Issues

1. Whether the appeal from the denial of an injunction became moot after the Louisiana court entered final judgment approving the settlement.
2. Whether the Anti–Injunction Act permitted a federal court to enjoin the Louisiana class action under the “necessary in aid of jurisdiction” or “protect or effectuate judgments” exceptions, as implemented through the All Writs Act.
3. Whether the federal MDL court’s role and the prior appellate vacatur of the federal settlement created a federal interest sufficient to justify an injunction against the state proceedings.
4. How comity and federalism considerations affected the propriety of enjoining a parallel state-court class settlement.

## Decision

- The Third Circuit held the appeal was not moot despite the Louisiana final judgment because it could still review the federal court’s refusal to enjoin and determine any appropriate federal-court consequences.
- The court affirmed the district court’s denial of an injunction.
- The Anti–Injunction Act barred the requested relief because none of its exceptions applied:
  - The MDL posture and case-management concerns did not make an injunction “necessary in aid of” federal jurisdiction.
  - The prior vacatur and remand did not constitute a final federal judgment that could be “protected or effectuated” via the relitigation exception.
  - No federal statute or rule expressly authorized an injunction in these circumstances.
- The court emphasized respect for state-court adjudicatory authority and declined to disturb the Louisiana judgment.

## Legal Principles

- The Anti–Injunction Act, 28 U.S.C. § 2283, is a strong bar against federal injunctions of state proceedings; its three exceptions are construed narrowly, with doubts resolved against federal interference.
- “Necessary in aid of jurisdiction” generally requires an exceptional threat to a federal court’s jurisdiction (often tied to in rem control or comparable exclusivity); MDL complexity alone is insufficient.
- The relitigation (“protect or effectuate judgments”) exception requires a prior final judgment that actually decided the matter sought to be barred; an order vacating a settlement and remanding for further proceedings does not supply the needed preclusive judgment.
- The All Writs Act cannot be used to evade the Anti–Injunction Act’s limits.
- Parallel state-court class actions are not barred merely because a federal MDL has addressed similar claims; comity and federalism support allowing competent state courts to proceed and to determine the effect of their judgments.

## Conclusion

The Third Circuit affirmed the refusal to enjoin a Louisiana state-court class settlement, holding that neither the existence of a federal MDL nor a prior appellate vacatur of a federal settlement triggered an Anti–Injunction Act exception, and that federal courts must generally refrain from interfering with parallel state proceedings absent a clear statutory basis.


In re Gen. Motors Corp. Pick-Up Truck Fuel Tank Prods. Liab. Litig., 134 F.3d 133 (3d Cir. 1998)