U.S. Supreme Court
Chick Kam Choo v. Exxon Corp., 486 U.S. 140 (1988)
Chick Kam Choo v. Exxon Corp.
Argued March 30, 1988
Decided May 16, 1988
486 U.S. 140
After Leong Chong, a Singapore resident, was accidentally killed in that country while performing repair work on a ship owned by one of the respondents, a subsidiary of the other respondent, his widow, petitioner Chick Kam Choo (hereafter petitioner), also a Singapore resident, brought suit in Federal District Court alleging various causes of action, including claims under the general federal maritime law and the Texas Wrongful Death Statute. In 1980, the court granted respondents summary judgment on the maritime law claim, concluding that applicable choice-of-law principles required that Singapore law, and not the maritime law of the United States, should apply. The court also dismissed the rest of the case on federalforum non conveniens grounds, provided that respondents submit to the Singapore courts' jurisdiction. Petitioner then filed suit in the Texas state courts under the Texas statutes and Singapore law, but the Federal District Court enjoined petitioner from prosecuting any claims relating to her husband's death in the state courts. The Court of Appeals affirmed, rejecting petitioner's contention that the injunction violated the Anti-Injunction Act (Act), which generally bars federal courts from enjoining state court proceedings. The court ruled that the injunction fell within the Act's "relitigation" exception, which permits a federal court to issue an injunction "to protect or effectuate its judgments."
Held: Because the District Court's injunction barring the state court proceedings is broader than is necessary "to protect or effectuate" that court's 1980 judgment dismissing petitioner's lawsuit from federal court, this case must be remanded for the entry of a more narrowly tailored order. Pp. 486 U. S. 145-151.
(a) An essential prerequisite for applying the Act's relitigation exception is that the claims or issues which the federal injunction insulates from state court litigation actually have been decided by the federal court. This prerequisite is strict and narrow, requiring an assessment of the precise state of the record and what the earlier federal order actually said; it does not permit a post hoc judgment as to what the order was intended to say. Atlantic Coast Line R. Co. v. Locomotive Engineers, 398 U. S. 281. chanroblesvirtualawlibrary
(b) Thus, since the 1980 judgment did not resolve the merits of petitioner's Singapore law claim, the injunction exceeded the Act's restrictions insofar as it barred the state courts from considering that claim. The 1980 judgment simply resolved that petitioner's claims should be dismissed under the federal forum non conveniens doctrine, and did not determine whether the state courts are an appropriate forum for the Singapore law claim. The Texas courts would apply a significantly different forum non conveniens analysis than the federal courts, and might well consider themselves an appropriate forum, in light of an "open courts" provision in the State Constitution. The argument that an independent state forum non conveniens determination is preempted under the "reverse-Erie" principle of federal maritime law, see, e.g., Offshore Logistics, Inc. v. Tallentire, 477 U. S. 207, 477 U. S. 222-223, cannot help respondents, since that preemption question was not actually litigated and decided by the District Court. When a state proceeding presents a federal issue, even a preemption issue, the proper course under the Act is to allow the state court to resolve the issue. Pp. 486 U. S. 148-150.
(c) Since petitioner's state law claim was necessarily adjudicated in the original federal action by the District Court's choice-of-law ruling that Singapore law controls petitioner's suit, the injunction, insofar as it barred the state courts from considering the state law claim, is within the scope of the relitigation exception, and is permissible under the Act. Pp. 486 U. S. 150-151.
(d) The fact that an injunction may issue under the Act does not mean that it must issue. On remand, the District Court should decide whether it is appropriate to enter an injunction. P. 486 U. S. 151.
817 F.2d 307, reversed and remanded.
O'CONNOR, J., delivered the opinion for a unanimous Court. WHITE, J., filed a concurring opinion. chanroblesvirtualawlibrary