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Parsons Steel, Inc. v. First Alabama Bank

United States Supreme Court

474 U.S. 518 (1986)

Relevant factsFree

Parsons Steel (plaintiff) sued First Alabama Bank (defendant) in both state and federal court over related claims; after the federal case resulted in judgment for the bank (following a jury verdict for Parsons that the judge overturned), the bank unsuccessfully raised res judicata in the still-pending state case, which then went to trial and produced a $4 million verdict for Parsons. The bank returned to federal court seeking to enjoin enforcement of the state verdict, and the district court granted the injunction under the relitigation exception to the Anti-Injunction Act, which the court of appeals affirmed without addressing the state court's own prior rejection of the bank's preclusion argument.

IssueFree

Whether a federal court may enjoin a party from enforcing a state court decision, even if that decision is arguably mistaken.

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