Marcus Huey v. Equitable Production Company, 27 F.4th 252

Federal class action (filed 2006) against EQT over royalty payments; district court approved a settlement (Final Settlement Agreement) effective Dec. 8, 2008 releasing "Royalty Claims" through that Effective Date and covering compensation period Feb. 1, 2000–Dec. 8, 2008.
Flat Rate Subclass members (including the Huey Plaintiffs) submitted claim forms, accepted settlement funds, and warranted ownership during the Compensation Period; claim form warned participants could not seek forfeiture of Flat Rate Leases after final judgment.
In 2017 the Huey Plaintiffs sued EQT in Wetzel County, WV, alleging trespass related to drilling and removal of hydrocarbons in 2013–2014, claiming the 1900 Hoge Lease had terminated earlier under its habendum/cessation clause due to nonproduction.
In 2020 EQT moved in federal court to enforce the 2008 settlement and enjoin the Wetzel County litigation as released/covered by the settlement and in breach of plaintiffs’ warranty; the district court denied the motion.
District court held the Wetzel County trespass claim is not a "royalty claim" as defined in the Agreement, and declined to enjoin the state suit under the Anti-Injunction Act; EQT appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Huey Plaintiffs are class members bound by the Agreement	Huey: are class members but their trespass claim falls outside the settlement release	EQT: Huey are class members and the district court should have enforced the settlement against them	Court assumed Huey were class members and found no error in district court's treatment
Whether the Wetzel County trespass claim is a "royalty claim" released by the Agreement	Huey: trespass is a state-law property claim, not a claim "based upon the failure to pay proper royalty," and occurred after the settlement period	EQT: trespass arises from the same contractual/royalty issues and was released by the Agreement and warranties	Held: Trespass is not a royalty claim under the Agreement and, in any event, occurred outside the settlement period (2013–14 vs. coverage through Dec. 8, 2008)
Whether exceptions to the Anti-Injunction Act permit enjoining the state suit	Huey: Anti-Injunction Act bars injunction; exceptions inapplicable	EQT: exceptions ("in aid of jurisdiction" and "relitigation") apply, so injunction warranted	Held: Exceptions do not apply; even if they did, injunction is discretionary and district court did not abuse its discretion in declining to enjoin

Atl. Coast Line R.R. Co. v. Brotherhood of Locomotive Eng'rs, 398 U.S. 281 (1970) (establishes narrow scope of Anti-Injunction Act exceptions and presumption in favor of state-court proceedings)
Chick Kam Choo, Ltd. v. Exxon Corp., 486 U.S. 140 (1988) (relitigation exception requires issues previously presented to and decided by the federal court)
Ackerman v. ExxonMobil Corp., 734 F.3d 237 (4th Cir. 2013) (district court has discretion whether to enjoin state proceedings even if an exception applies)
In re Am. Honda Motor Co., 315 F.3d 417 (4th Cir. 2003) (discusses scope of relitigation exception to Anti-Injunction Act)
Nationwide Mut. Ins. Co. v. Burke, 897 F.2d 734 (4th Cir. 1990) (party invoking relitigation exception must make a strong and unequivocal showing)
Sandpiper Village Condo. Ass’n, Inc. v. La.-Pac. Co., 428 F.3d 831 (9th Cir. 2005) ("in aid of jurisdiction" exception did not justify enjoining state litigation after class action long resolved)
Smith v. Bayer Corp., 564 U.S. 299 (2011) (courts should generally permit state-court proceedings to proceed absent narrow statutory exceptions)