Smith v. Bayer Corporation
United States Supreme Court
131 S. Ct. 2368 (2011)
Relevant factsFree
After a federal court denied class certification in McCollins's separate suit against Bayer (defendant) applying Federal Rule 23, Bayer got the same federal court to enjoin a similarly situated, later-filed state suit by Smith (plaintiff), who was neither a named party nor a class member in the McCollins action, from deciding its own class-certification motion under West Virginia's differently interpreted Rule 23.
IssueFree
Whether a federal court may enjoin a state court from deciding an issue under the Anti-Injunction Act, 28 U.S.C. § 2283, if (1) the issue is governed by a different legal standard than the federal court applied or (2) the parties to be bound are not identical.