Bordelon v. Jefferson Feed & Garden Supply, Inc.

703 F. Supp. 25, 1988 U.S. Dist. LEXIS 13089, 1988 WL 144825
CourtDistrict Court, E.D. Louisiana
DecidedNovember 9, 1988
DocketCiv. A. No. 88-992
StatusPublished
Cited by1 cases

This text of 703 F. Supp. 25 (Bordelon v. Jefferson Feed & Garden Supply, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bordelon v. Jefferson Feed & Garden Supply, Inc., 703 F. Supp. 25, 1988 U.S. Dist. LEXIS 13089, 1988 WL 144825 (E.D. La. 1988).

Opinion

ORDER AND REASONS

MENTZ, District Judge.

On October 4, 1988 the defendant, Donald Shephard, filed an application to enjoin the Twenty-Fourth Judicial District Court for the Parish of Jefferson, State of Louisiana, from exercising personal jurisdiction over him. The application was subsequently taken under submission without oral argument. In this application Shephard argues under Rule 65 of the Federal Rules of Civil Procedure and 28 U.S.C. Section 2283 that the state court should be enjoined from relitigation of this issue because he has already been adjudged by this Court to be outside the jurisdiction of .Louisiana. The Court, after reviewing the record, the memoranda of counsel, and the applicable law, grants defendant’s application for a permanent injunction of state court proceedings for the reasons set forth below.

FACTS

On February 27, 1987, Dale Bordelon brought suit in a Louisiana state court against Jefferson Feed and Garden Supply, Inc. (Jefferson Feed) for damages resulting from the death of Bordelon’s race horse. The horse’s death was allegedly caused by ingestion of beetle-infested hay sold by Jefferson Feed to Joe Gleber Racing Stables, Bordelon’s stabler. One year later, Jefferson Feed brought a third party demand for indemnity and/or contribution against Donald Shephard, an Oklahoma resident. Allegedly, the infested hay had been grown by Shephard and sold to Jack McCracken, another Oklahoma resident. McCracken had, in turn, re-sold the hay to Jefferson Feed.

Shephard removed the entire case to this Court pursuant to 28 U.S.C. Section 1441(c). Mr. Shephard subsequently moved this Court to dismiss him for lack of personal jurisdiction. On the other hand, Mr. Bordelon moved that the case be remanded back to state court. On July 20, 1988, oral arguments were heard and both motions were granted. The Court treated Mr. Shephard’s motion as one for summary judgment under Rule 56 of the Federal Rules of Civil Procedure.

Once back in state court, Mr. Bordelon filed a supplemental petition on August 26, 1988, naming Shephard as an additional defendant. As a result, Mr. Shephard now asks this Court enjoin the Louisiana state court from exercising personal jurisdiction over him.

ANALYSIS

The Anti-Injunction Act generally prohibits federal courts from granting injunctions to stay proceedings in state courts:

A court of the United States may not grant an injunction to stay proceedings in a State Court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments. 28 U.S.C. sec. 2283.

By barring such federal court intervention, the Act “prevent[s] needless friction between state and federal courts. . . .” Atlantic Coast Line R. Co. v. Locomotive Engineers, 398 U.S. 281, 286, 90 S.Ct. 1739, 1743, 26 L.Ed.2d 234 (1970) (citation omitted).

[27]*27On its face, the Act absolutely prohibits injunctions of state court proceedings unless the injunction falls under one of the three specifically defined exceptions. Id. These exceptions are designed to ensure the effectiveness and supremacy of federal law, but are not to be construed broadly. Chick Kam Choo v. Exxon Corp., — U.S. -, 108 S.Ct. 1684, 1689, 100 L.Ed.2d 127 (1988). See also Atlantic Coast Line, 398 U.S. at 286-87, 90 S.Ct. at 1743-44 (rejecting the idea that the Act establishes only a discretionary “principle of comity”). Only the last of the these three exceptions, “to protect or effectuate its judgments,” is applicable in the present case. The issue thus becomes whether an injunction is necessary “to protect or effectuate” this Court’s judgment dismissing the defendant for lack of personal jurisdiction.

The Supreme Court has recognized that, “a federal court does not have inherent power to ignore the limitations of Section 2283 and enjoin state court proceedings merely because those proceedings interfere with a protected federal right or invade an area pre-empted by federal law, even when the interference is unmistakably clear.” Atlantic Coast Line, 398 U.S. at 294, 90 S.Ct. at 1746. Rather, the relitigation exception was designed to permit a federal court to prevent a state court from relitigating issues decided by the federal court. Chick Kam Choo, 108 S.Ct. at 1690. It is grounded in the well-recognized concepts of res judicata and collateral estoppel. Id. However, the relitigation exception is limited to those claims acutally decided by the federal court. Id. This prevents the federal court from issuing an injunction based on a post hoc interpretation of its prior decision. Atlantic Coast Line, 398 U.S. at 290-93, 90 S.Ct. at 1744-46.

In Chick Kam Choo, a resident of the Republic of Singapore brought suit against Exxon in the United States District Court for the Southern District of Texas. The suit involved various claims for the alleged wrongful death of her husband, who was killed while performing repair work in Singapore aboard a ship owned by Exxon. The District Court concluded under a choice-of-law analysis that United States law should not be applied, and subsequently dismissed the case based on forum non conveniens grounds. Rather than commence litigation in Singapore, however, the plaintiff filed suit in Texas state court. The defendants then returned to the District Court and requested an injunction to prevent the plaintiff from relitigating in the state forum any issues decided by the federal court. The District Court granted the motion, and the Fifth Circuit upheld the injunction. The Supreme Court reversed, noting that Texas state courts might apply an altogether different forum non conveniens analysis, or indeed, no such analysis at all.1 Therefore, whether the Texas state courts were an appropriate forum for the plaintiff’s Singapore law claims had not yet been litigated, and an injunction to foreclose consideration of that issue was not within the relitigation exception. Chick Kam Choo, 108 S.Ct. at 1691. However, the Court permitted the injunction with respect to that part of the District Court’s decision regarding choice-of-law. The Court noted that a decision respecting choice-of-law “necessarily precludes the application of Texas law” and was within the scope of Section 2283. Id. at 1692.

Atlantic Coast Line makes clear that the relitigation exception to Section 2283 is limited to those claims actually decided by the federal court. Chick Kam Choo, 108 S.Ct. at 1690. The District Court, in Chick Kam Choo actually decided only the choice-of-law and federal forum non conveniens issues. Thus, the significantly different forum non conveniens

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Bluebook (online)
703 F. Supp. 25, 1988 U.S. Dist. LEXIS 13089, 1988 WL 144825, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bordelon-v-jefferson-feed-garden-supply-inc-laed-1988.