Trustees of the Carpenters’ Health and Welfare Trust Fund of St. Louis v. Darr

Dist. Ct. erred in granting plaintiffs-trustees of welfare fund's request for entry of permanent injunction to restrain defendant-law firm from proceeding with state-court action against plaintiff that attempted to collect under common fund doctrine legal fees and costs from settlement proceeds of personal injury action that had been filed by beneficiary of said fund. While plaintiffs argued that, due to language in plan, plan was entitled to reimbursement of all medical expenses that had been advanced to beneficiary without any deduction for legal fees and costs generated in personal injury action, Anti-Injunction Act precluded plaintiffs from seeking injunction of state-court proceeding. Fact that defendant's state-court proceeding could force plaintiffs to pay portion of defendant's fees in violation of plan's language did not require different result where state-court action did not either directly involve recovery of benefits under plan or prevent plan's trustees from fulfilling their duties under ERISA since trustees can present their federal defenses in state-court action and can seek damages should state-court reject said defenses.