Venue: |
SCOTUS
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Facts: |
Ridiculously complicated. Union picketing of railroad facilities,
lots of complexities. |
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Posture: |
A ton of different stuff not even included in the edited case...
basically battling rulings by state and federal courts. The
feds say the union can picket, and the state tries to circumvent
that. |
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Issue: |
Can federal courts enjoin state courts when state proceedings interfere
with federal rights? |
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Holding: |
No. |
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Rule: |
Lower federal courts possess no power to sit in review of state court
decisions. |
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Reasoning: |
The Anti Injunction Act doesn't contain an exception for this sort
of federal court action. When the state court has concurrent
jurisdiction, the federal court isn't free to prevent a party
from pursuing claims there (and vice-versa). Any doubts on
this point should be resolved in favor of letting the state
courts settle the controversy. |
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Dicta: |
Brennan (dissenting): The nonintervention policy is hardly absolute,
as the exceptions described in the Act make clear. And so state
proceedings shouldn't be allowed to undermine a prior judgment
of a federal court, and that's what is happening here. |
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