Smith v. Bayer Corp.
131 S. Ct. 2368
| SCOTUS | 2011Background
- Federal District Court enjoined West Virginia state court from hearing Smith's class-certification motion after denying McCollins’ similar motion in a separate Baycol case.
- McCollins sought class certification under West Virginia Rule 23; District Court denied, and injunction was issued to preclude Smith’s state-court action.
- Eighth Circuit affirmed the injunction, relying on the relitigation exception to the Anti-Injunction Act and claiming Smith was bound as a nonparty in a putative class.
- West Virginia Supreme Court's interpretation of Rule 23 and the state court's approach differed from federal Rule 23, creating potential for divergent rulings.
- Question presented: whether the federal court properly invoked the relitigation exception to enjoin state-court certification proceedings.
- Supreme Court reversed, holding the relitigation exception does not authorize the injunction because the issues and parties do not align and binding nonparties rule is not satisfied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the relitigation exception allow federal injunction of state-court class certification? | Smith argues preclusion logic could bind nonparties; federal court rejected state proceeding. | Bayer asserts identical issues and need to protect federal judgment justify injunction. | No; injunction improper under relitigation exception. |
| Were the federal and state issues identical for preclusion to apply? | States' Rule 23 analysis mirrors federal Rule 23; issues effectively same. | State and federal standards differ; issues not identical. | Issues not identical; injunction invalid. |
| Is Smith bound as a nonparty to McCollins’ suit as an unnamed class member? | Smith should be bound via class-action preclusion. | McCollins’ suit was not certified as a class; nonparty binding not applicable. | Smith not bound as nonparty; no preclusion. |
| Do differing state and federal Rule 23 interpretations preclude injunction? | There is substantial overlap; preclusion should apply. | Different rules and standards lead to different issues. | Different standards mean different issues; injunction inappropriate. |
| Does CAFA or other remedies address relitigation concerns without injunctive relief? | CAFA provides removal pathway and coordination between courts. | CAFA not controlling here; preclusion should suffice. | CAFA provides alternatives; injunction unnecessary. |
Key Cases Cited
- Chick Kam Choo v. Exxon Corp., 486 U.S. 140 (1988) (relitigation exception is narrow; requires same issue and preclusion-like grounds)
- Atlantic Coast Line R. Co. v. Locomotive Engineers, 398 U.S. 281 (1970) (anti-injunction act; presumption against injunctions against state courts)
- Taylor v. Sturgell, 553 U.S. 861 (2008) (nonparty preclusion; virtual representation rejected; binding nonparties only via proper class action)
- In re Rezulin Litigation, 214 W. Va. 52, 585 S.E.2d 52 (2003) (West Virginia Rule 23 predominance analysis; differs from federal approach)
- In re BridgeStone/Firestone, Tires Prods. Liability Litigation, 333 F.3d 763 (7th Cir. 2003) (class-action preclusion concerns; limits on binding nonparties)
- In re Baycol Prods. Litigation, 593 F.3d 716 (8th Cir. 2010) (centerpiece case; relitigation exception and preclusion scope)