Bridgeport MacHines, Inc. v. Alamo Iron Works, Inc.

76 F. Supp. 2d 209, 1999 U.S. Dist. LEXIS 19156, 1999 WL 1140376
District Court, D. Connecticut·Decided July 9, 1999·No. 3:98CV313(JBA)·Published·Cited by 3 cases

Opinion

RULING ON PLAINTIFF’S MOTION TO ENJOIN A SUBSEQUENTLY-FILED RELATED STATE COURT ACTION OF DEFENDANT ALAMO WORKS, INC. AND FOR OTHER RELIEF [DOC. #25]

ARTERTON, District Judge.

Plaintiff Bridgeport Machines, Inc. (“Bridgeport Machines”), requests that *211 this Court issue an order enjoining a related state court action filed by Defendant Alamo Iron Works, Inc. (“Alamo”) in Texas state court, Alamo Iron Works, Inc. v. Southwest Indus. Co., Brad Gatlin, Edward Hilinski, Michael S. Lamonica, Jr., and Bridgeport Mach., Inc., 28th Judicial District, Bexar County, No. 98-CI-05625 (“Texas state court action”).

Description of State and Federal Actions

Plaintiff filed the Complaint in this federal action in February 1998, and summonses were executed on each of the defendants in April 1998. In this diversity action, plaintiff Bridgeport Machines seeks a declaratory judgment with ancillary relief declaring its past, present and future legal relations with each of the defendants arising from its separate distribution agreements permitting defendants to market, advertise, and sell plaintiffs machine tools. Plaintiffs Amended Complaint generally seeks declaratory relief that each defendant’s request that plaintiff refuse to deal with other entities within what they claim to be their exclusive contract sales territory is violative of plaintiffs “commercial relations with other entities and federal law.” (Am.Compl. at ¶ 33).

In August 1998, Alamo added Bridgeport Machines, Brad Gatlin, Edward Hi-linski, and Michael Lamonica, Jr., to the Texas state court action it had initiated originally against only Southwest Industrial Sales alleging tortious interference with present and prospective business and employee relationships based on its exclusive territory. In its Amended Petition, Alamo alleges Bridgeport Machines breached its contract and tortiously interfered with its employee relations arising from its claim of a contractually exclusive sales territory. {See [Alamoj’s First Am. Original Pet., Ex. C, PI. [Bridgeport] Mem. of Law).

On September 4, 1998, plaintiff filed this motion seeking to enjoin the Texas state court action. On October 16, 1998, the Court granted the parties’ Joint Motion and Stipulation for Reference to Mediation and For Stay of Proceedings, [doc. # 41], which stated “[t]his action shall be stayed as to these parties pending completion of the mediation process.” The parties met with the mediator on January 6, 1999, but were unable to reach a settlement. As a result, this Court lifted the stay and has ordered this matter to be trial ready as of January 2000. Since the Texas state court action was not affected by the stay entered in this action, the Texas court has ordered its trial to commence on August 9, 1999.

Standard for Enjoining State Court Action

Although Bridgeport Machines’ motion does not specify on what basis it invokes this Court’s authority, the All Writs Act, 28 U.S.C. § 1651, confers injunctive power, “if otherwise proper on the federal courts to issue all writs necessary or appropriate in aid of their respective jurisdiction and agreeable to the usages and principles of law.” However, the All Writs Act does not authorize federal courts to enjoin state court actions where such injunction is expressly prohibited under the Anti-Injunction Act, (unless certain limited circumstances apply). See 28 U.S.C. § 2283; Olin v. Ins. Co. of N. Am., 807 F.Supp. 1143, 1152 (S.D.N.Y.1992); Atlantic Coast Line Railroad Co. v. Brotherhood of Locomotive Engineers, 398 U.S. 281, 286-287, 90 S.Ct. 1739, 26 L.Ed.2d 234 (1970).

Section 2283 provides:

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.

“Proceedings in state courts should normally be allowed to continue unimpaired by intervention of lower federal courts, with relief from error, if any, through the state appellate courts and ultimately [the Supreme] Court.” Atlantic Coast Line, 398 U.S. at 286-87, 90 S.Ct. 1739. The purpose of the Anti-Injunction Act is “to prevent needless friction be *212 tween state and federal court,” Mitchum v. Foster, 407 U.S. 225, 232-233, 92 S.Ct. 2151, 32 L.Ed.2d 705 (1972)(internal citations omitted) and as a result, “the question of whether to stay the proceedings in a state court is never one to be taken lightly, as it impinges on the very delicate balance struck between the federal and state judicial systems.” Olin Corp. v. Insurance Co. of N. Am., 807 F.Supp. 1143, 1152 (S.D.N.Y.1992). The Anti-Injunction Act’s three exceptions have been strictly construed by courts with the general proviso that “any doubts as to the propriety of a federal injunction against state court action should be resolved in favor of permitting the state courts to proceed in an orderly fashion to finally determine the controversy.” Atlantic Coast Line, 398 U.S. at 297, 90 S.Ct. 1739.

If a case comes within the Anti-Injunction Act and does not fit one of its exceptions, a federal court is absolutely barred from enjoining state court proceedings. However, the inverse is not necessarily true. Even if the case falls within one of the exceptions, the party seeking such injunctive relief must still address the principles of equity, comity and federalism that restrain a court from enjoining a state court proceeding. See e.g., Chick Kam Choo v. Exxon Corp., 486 U.S. 140, 151, 108 S.Ct. 1684, 100 L.Ed.2d 127 (1988) (“Of course, the fact an injunction may issue under the Anti-Injunction Act does not mean that it must issue.”).

Discussion

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Bridgeport MacHines, Inc. v. Alamo Iron Works, Inc., 76 F. Supp. 2d 209, 1999 U.S. Dist. LEXIS 19156, 1999 WL 1140376 (D. Conn. 1999).

76 F. Supp. 2d 209 (Bridgeport MacHines, Inc. v. Alamo Iron Works, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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