## Facts

- Hurley Henson filed a Louisiana state-court tort action alleging injury from exposure to a chlordimeform-based insecticide manufactured or sold by Syngenta-related entities.
- A similar federal products-liability class action was pending in the Southern District of Alabama, and Henson intervened; his Louisiana action was stayed.
- The federal action settled, and the settlement contemplated dismissal with prejudice of Henson’s Louisiana case, but the Louisiana court allowed that case to proceed.
- Syngenta removed the Louisiana case to the Middle District of Louisiana under 28 U.S.C. § 1441(a), asserting federal authority grounded in the All Writs Act (28 U.S.C. § 1651) and supplemental jurisdiction (28 U.S.C. § 1367) to protect and enforce the federal settlement.
- The removed case was transferred to the Southern District of Alabama, which dismissed Henson’s claims as barred by the federal settlement.
- The Eleventh Circuit vacated, holding § 1441 requires original federal jurisdiction and the All Writs Act does not itself confer subject-matter jurisdiction; the Supreme Court granted certiorari.

## Issues

1. Whether the All Writs Act, alone or together with ancillary enforcement authority, can supply the “original jurisdiction” required for removal under 28 U.S.C. § 1441(a).
2. Whether a federal court may remove a state-court action to protect or effectuate a prior federal settlement when the removed action lacks an independent basis for federal subject-matter jurisdiction.

## Decision

- The Supreme Court unanimously affirmed the Eleventh Circuit.
- The All Writs Act does not furnish removal jurisdiction, either alone or when paired with ancillary enforcement jurisdiction.
- Because removal under § 1441(a) is limited to cases within the district court’s original subject-matter jurisdiction, the attempted removal was improper.

## Legal Principles

- Removal is governed by statute; courts may not use the All Writs Act to bypass statutory limits on removal.
- The All Writs Act is a residual authority to issue writs “in aid of” existing jurisdiction; it does not create federal subject-matter jurisdiction.
- Section 1441(a) permits removal only for actions of which federal district courts have original jurisdiction; ancillary enforcement authority is not a substitute for original jurisdiction.
- Federal courts may protect and enforce their judgments through appropriate orders within their jurisdiction, but that power does not authorize removal of otherwise nonremovable state actions.

## Conclusion

The Court held that a state-court action cannot be removed to federal court based solely on a federal court’s interest in enforcing a prior settlement: § 1441(a) requires an independent basis for original federal jurisdiction, and the All Writs Act cannot supply it.


Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28 (2002)