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
- 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).
- 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.