United States v. Manne, No. 12-3079 (2d Cir. 2013)Annotate this Case
This case arose when appellant settled an environmental enforcement action brought against him by the United States through a consent decree providing, inter alia, that defendant would pay the government an amount equal to the fair market value of a parcel of real property owned by appellant. At issue on appeal was whether a district court, under the All Writs Act, 28 U.S.C. 1651(a), and the Anti-Injunction Act, 22 U.S.C. 2283, had the authority to enjoin a party from litigating in state court issues arising out of the consent decree which settled the civil action brought against the party in federal court by the United States. The court held that the Anti-Injunction Act did not permit the district court in this case to enjoin appellant's state court suit. Accordingly, the court vacated the injunction, concluding that the district court erred by relying on the "in aid of jurisdiction" exception to the Anti-Injunction Act in enjoining appellant's state court suit.