O’Keefe v. Chisholm

Dist. Ct. erred in issuing injunction that blocked State of Wisconsin from conducting judicially supervised criminal investigation into question as to whether certain persons violated state’s campaign-finance laws by coordinating fundraising efforts with independent group that was raising and spending money on particular issues. Instant injunction contravened Anti-Injunction Act, which prohibits Dist. Ct. from issuing injunction to stay state-court proceeding unless expressly authorized to do so or where necessary in aid of its jurisdiction or to effectuate its judgment. Moreover, Dist. Ct. should not have intervened in state-court matter where: (1) plaintiff in instant case had received relief in state court by obtaining order that stopped investigation as matter of state law; (2) investigation pertained to criminal matter; (3) Dist. Ct. failed to consider principles of federalism, comity and equity prior to issuing injunction; and (4) legal uncertainty as to definition of “coordination” precluded finding that instant investigation was done in bad faith.