This case began as a class action by farmers in
Louisiana for illness caused by Ciba-Geigy insecticide.
The Louisiana farmers then intervened in a separate
class action in federal district court in Alabama.
That case ended in a settlement. Unhappy with that
result, the Louisiana farmers resumed their action
in Louisiana state court, which ruled that the settlement
did not resolve all their claims. Defendant moved
to bring the case back into federal court, asserting
jurisdiction under the All Writs Act, which provides
that federal courts "may issue all writs necessary
or appropriate in aid of their respective jurisdictions."
The
case was removed to Louisiana federal court, which
transferred it to the Alabama federal court, which
dismissed the action as barred by the settlement.
The Eleventh Circuit reversed, aligning itself with
those circuits narrowly interpreting the All Writs
Act. The Supreme Court granted cert to resolve the
circuit split.
AAJ as amicus argued that the All Writs Act does
not itself provide a basis for federal jurisdiction.
The Act should be narrowly construed to preserve
the independence of state court judicial systems.
State courts are competent to determine the preclusive
effect of a prior settlement in federal court, and
there is no necessity to expand federal jurisdiction
at the expense of state courts.
Chief Justice Rehnquist, writing for a unanimous
Court, affirmed. The Court held that the All Writs
Act provides no independent basis for removal jurisdiction.
The Court emphasized that "a suit commenced
in a state court must remain there until cause is
shown for its transfer under some act of Congress."