Adkins v. Nestle Purina PetCare Co.

Dist. Ct. erred in entering injunction in instant nationwide federal class action that enjoined class members from pursuing Missouri statewide class action that raised similar claims against defendants. Record showed that statewide class action was scheduled for trial in May of 2015, while settlement of instant federal class action was not scheduled for fairness hearing until June 23, 2015. As such, entry of instant injunction violated Anti-Injunction Act (Act) since: (1) although statewide action might serve to derail settlement in federal action, Dist. Ct. failed to explain how entry of injunction was necessary in aid of Dist. Ct.’s jurisdiction in federal class action; and (2) instant parties have not contended that judgment in statewide action could threaten Dist. Ct.’s ability to adjudicate federal class action. Moreover, Act provides only limited opportunities for federal intervention into parallel state-court actions and leaves to state court question as to whether it would be prudent to allow federal court to initially resolve similar claim.