Barroway v. Computer Assoc., et. al., No. 10-4785 (2d Cir. 2012)Annotate this Case
In this action under the All Writs Act, 28 U.S.C. 1651, and the Anti-Injunction Act, 28 U.S.C. 2283, the court considered whether, following the approval of a federal class action settlement, the district court properly enjoined a state court action for legal malpractice directed at counsel for the plaintiff class. The court held that the "in aid of jurisdiction" exception to the Anti-Injunction Act could not form the basis for the district court's injunction of the state court action, as the limited circumstances in which the injunction of an in personam action could be appropriate "in aid of" the court's jurisdiction were not present in this case. The court also concluded that where, as here, the parties had a full and fair opportunity to litigate the reasonableness of counsel's representation, a subsequent malpractice action could be enjoined under the relitigation exception.