Using The Anti-Injunction Act In Class Actions

Law360, New York (July 22, 2011, 11:04 AM EDT) -- While the Anti-Injunction Act is more than 200 years old, it has been brought to the forefront of products liability litigation in a recent opinion by the United States Supreme Court, Smith, et al., v. Bayer Corp., No. 09-1205 (U.S. June 16, 2011).

Though the court resolved and clarified two circuit splits on the application of the act's relitigation exception, it did not break much new ground, holding that the act's relitigation exception applies only under strict circumstances with all doubt resolved against enjoining state court...
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