## Facts

- A class action concerning property taken from Hungarian Jews during World War II resulted in a settlement creating a fund for social services and humanitarian relief.
- The settlement approval order provided that the Southern District of Florida retained exclusive and continuing jurisdiction to enforce the settlement and its obligations.
- A class member, Robert Langermann, received benefits through designated agencies but objected to their administration, including requests for financial information and a home visit, and asserted he sometimes received less than $2,500 per year.
- Langermann moved in the Southern District of Florida to hold the administering agencies in contempt for allegedly violating the settlement; the court denied the motion.
- Langermann then filed a separate federal action in the District of Nevada against the Florida judge, lead class counsel, and administering agencies, alleging a conspiracy to deprive him of settlement benefits.
- Lead class counsel moved in the Southern District of Florida to enjoin the Nevada litigation; the court granted an injunction barring Langermann from prosecuting the Nevada case.

## Issues

1. Whether the Southern District of Florida had subject-matter or ancillary jurisdiction to enjoin a class member’s collateral federal action challenging settlement administration.
2. Whether the All Writs Act, 28 U.S.C. § 1651, authorized an injunction to protect the settlement and the court’s retained jurisdiction.
3. Whether the Anti-Injunction Act, 28 U.S.C. § 2283, barred the injunction, or whether an exception applied.

## Decision

- The Eleventh Circuit affirmed the injunction.
- The court held that the district court had jurisdiction to enforce its settlement approval order and to prevent collateral attacks that threatened that enforcement.
- The court concluded the All Writs Act authorized injunctive relief necessary or appropriate in aid of the district court’s jurisdiction over settlement enforcement.
- The court held the Anti-Injunction Act did not bar the injunction because it fit within an exception permitting injunctions necessary to protect or effectuate the court’s judgments (and to aid its jurisdiction over the settlement).

## Legal Principles

- A federal court that approves a class action settlement and expressly retains jurisdiction may exercise ancillary jurisdiction to enforce the settlement and its approval order.
- Under the All Writs Act, a court may enjoin proceedings that would frustrate or impair the court’s ability to administer and enforce its judgments, including complex class settlements.
- The Anti-Injunction Act permits federal injunctions against other proceedings when necessary to protect or effectuate the issuing court’s judgments (relitigation exception) and when needed to preserve the court’s jurisdiction over settlement enforcement.

## Conclusion

The Eleventh Circuit upheld an injunction preventing a settlement class member from pursuing collateral federal litigation that threatened to relitigate or circumvent the settlement framework and the approving court’s continuing authority to enforce its final approval order.


Rosner v. United States, 517 F. App’x 762 (11th Cir. 2013)