Huey v. Equitable Production Co., No. 21-1614 (4th Cir. 2022)
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This appeal involves a motion to enforce the final judgment and final order in a class action settlement made in the district court by the defendant in the class action, EQT, and class members, the Huey Plaintiffs. The Huey Plaintiffs subsequently filed suit in the Circuit Court of Wetzel County, West Virginia (the Wetzel County litigation) against EQT three years after the entry of the final judgment and final order, alleging that EQT trespassed on their mineral estate in violation of West Virginia statutory and common law. After the district court denied the final judgment and final order and declined to enjoin the Wetzel County litigation, EQT appealed.
The Fourth Circuit affirmed the district court's denial of EQT's motion to enforce the final judgment order and final order, concluding that the district court did not err in declining to enjoin the Wetzel County litigation. The court found no error in the district court's assumption that the Huey Plaintiffs were class members bound by the Settlement Agreement. The court agreed with the district court's holding that the trespass claim in the Wetzel County litigation is not a royalty claim and not released by the Agreement. Finally, the court concluded that the district court did not abuse its discretion in not issuing an injunction and by finding that two exceptions to the Anti-Injunction Act, the "in aid of jurisdiction" and the relitigation exceptions, did not apply in this case.
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