## Facts

- A Wisconsin village sued a property owner in state court to obtain an order to raze unsafe residential structures and recorded a lis pendens.
- The first suit was dismissed on technical grounds and promptly refiled, but no new lis pendens was recorded for the refiled action.
- The state court entered judgment in the refiled action ordering the buildings razed and awarding $629.42 in damages and costs.
- The clerk’s judgment docket entry reflected only the money award and did not mention the raze order.
- After the judgment became final, deeds transferring the property were recorded; Donald W. Pelfresne later purchased the property, asserting he lacked actual or constructive notice of the raze order.
- When the village attempted to execute the raze order, Pelfresne filed a federal diversity action seeking to enjoin enforcement and claimed bona fide purchaser status under Wisconsin law.
- The district court dismissed the suit as barred by the Anti-Injunction Act and denied leave to amend.

## Issues

1. Whether the Anti-Injunction Act, 28 U.S.C. § 2283, barred a federal court from enjoining enforcement of a state-court raze judgment against a subsequent purchaser in privity with the state-court defendants.
2. Whether, under Wisconsin recording and notice rules, the raze order bound a subsequent bona fide purchaser when no lis pendens was filed for the refiled action and the judgment docket omitted the raze order.

## Decision

- The Seventh Circuit affirmed dismissal because § 2283 barred the requested injunction against enforcement of the state-court judgment.
- The court treated Pelfresne as in privity with his predecessors in title for purposes of applying § 2283.
- The court indicated that, under Wisconsin law, the raze order likely did not bind a bona fide purchaser because the mechanisms for constructive notice were not properly used (no lis pendens for the refiled suit; docket did not mention the raze order).
- The court affirmed denial of leave to amend as futile because the suit’s core objective remained an impermissible federal injunction against state judgment enforcement.

## Legal Principles

- Under 28 U.S.C. § 2283, federal courts generally may not enjoin state-court proceedings or enforcement of state judgments absent a statutory exception (express congressional authorization, necessity in aid of jurisdiction, or protection/effectuation of federal judgments).
- The § 2283 bar applies when a federal plaintiff, including one in privity with a state-court party, seeks relief that would functionally nullify or impede enforcement of a state judgment.
- Alleged state-law errors in a completed state-court judgment ordinarily must be addressed through state-court remedies, not by collateral federal injunctive relief.
- Under Wisconsin notice concepts discussed by the court, constructive notice for litigation affecting real property depends on proper recording devices (such as a lis pendens for the operative action) and on what the judgment docket entry reflects for lien/notice purposes.

## Conclusion

The Seventh Circuit held that the Anti-Injunction Act barred a federal injunction to stop enforcement of a state-court raze order against a later purchaser in privity with the original defendants, leaving any challenge to the raze order’s effect on the purchaser to the state courts.


Pelfresne v. Village of Williams Bay, 917 F.2d 1017 (7th Cir. 1990)