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Keywords

plaintiffdefendantjurisdictiondamagesinjunctionappealclass actionappellee
settlementtortplaintiffdefendantjurisdictiondamagesinjunctionclass actioncivil procedureappellantappelleedeclaratory judgment

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Carlough v. Amchem Products, Inc., 10 F.3d 189, 62 USLW 2377

Facts

The Gore plaintiffs, absent members of a federal class action for asbestos-related damages, initiated a separate class action in West Virginia against the same defendants before the federal court established an opt-out period. The federal district court issued a preliminary injunction to prevent the Gore plaintiffs from pursuing their state claims, arguing that it was necessary to protect its jurisdiction. The Gore plaintiffs contended that the injunction was invalid due to the lack of personal jurisdiction and the absence of an opt-out opportunity.

The appellants, the “Gore plaintiffs”, are absent members of a purported federal plaintiff class in an action brought pursuant to Federal Rule of Civil Procedure 23(b)(3) for asbestos-related tort damages in the United States District Court for the Eastern District of Pennsylvania.

Issue

Did the district court have personal jurisdiction over the absent plaintiffs, and was the issuance of the preliminary injunction premature given that the plaintiffs had not yet been afforded the opportunity to opt out of the federal class action?

The Gore plaintiffs first asserted that the injunction was not binding on them because it purported to be effective outside of the jurisdictional reach of the federal district court.

Rule

A federal court may issue an injunction to stay state court proceedings only as expressly authorized by Congress or where necessary in aid of its jurisdiction, as per the Anti-Injunction Act and the All-Writs Act. Additionally, personal jurisdiction over absent class members requires either minimum contacts with the forum or an opportunity to opt out of the class action.

The Anti–Injunction Act provides that: 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.

Analysis

The court determined that the district court did not have personal jurisdiction over the Gore plaintiffs at the time the injunction was issued, as they had not been notified of the federal class action or given the opportunity to opt out. The court emphasized that the lack of personal jurisdiction rendered the injunction premature. However, once the district court resolved its jurisdictional challenges and established an opt-out period, it recognized its authority over the Gore plaintiffs.

The court characterized the sole purpose of the Gore action as “preemptive” of the federal class action.

Conclusion

The Court of Appeals affirmed the district court's injunction as necessary in aid of its jurisdiction, but noted that the initial issuance was premature due to the lack of personal jurisdiction over the absent plaintiffs. The court ultimately recognized the district court's jurisdiction following its subsequent orders.

Affirmed.

Who won?

The appellees, represented by the Center For Claims Resolution, prevailed because the court upheld the injunction as necessary to protect the federal court's jurisdiction over the class action.

The appellees, numerous asbestos producers jointly represented by the Center For Claims Resolution (the “CCR”) and named as defendants in both actions, assert that the district court may consider the merits of the proposed settlement agreement filed simultaneously with the federal class action complaint before the state court entertains the Gore plaintiffs' request for declaratory judgment.

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