Petitta v. 3M Company, No. 19-2932 (8th Cir. 2021)
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The Eighth Circuit reversed and vacated the district court's permanent injunction enjoining plaintiff from litigating claims against 3M in Texas state court, where he had filed suit three years earlier. The parties had previously agreed to dismiss with prejudice similar claims that plaintiff brought against 3M in a multidistrict litigation (MDL) in federal court. The district court concluded that this previous dismissal had preclusive effect in the Texas case, authorizing it to enjoin the state court proceedings under the relitigation exception to the Anti-Injunction Act.
Applying Texas choice-of-law principles and Texas substantive law, the court concluded that it is evident that the stipulated dismissal with prejudice in plaintiff's MDL case was simply an agreement to dismiss and was therefore not a final judgment on the merits. Accordingly, plaintiff's claims in Texas state court are not precluded under Texas law. Because plaintiff's state law claims were not previously presented to and decided by the federal court, the relitigation exception of the Anti-Injunction Act has no effect in this case.
Court Description: [Kelly, Author, with Gruender and Grasz, Circuit Judges] Civil Case - Products Liability - Injunction. District court permanently enjoined litigation in Texas state court of claims parties had previously agreed to dismiss with prejudice in multidistrict litigation in federal court, concluding dismissal had preclusive effect. Petitta appeals, arguing the religation exception to the Anti-Injunction Act does not apply. As to the choice of law, considering this was an MDL case sitting in diversity and Petitta filed in Minnesota pursuant to the standing order, Texas choice-of-law applies and Texas substantive law governs. Applying Texas law, the dismissal with prejudice was simply an agreement to dismiss, was not a settlement of the MDL claims, and did not resolve claims on the merits. Thus, the dismissal "with prejudice" was not a final judgment on the merits and the claims in Texas state court were not precluded under Texas law. The relitigation exception to the Anti-Injunction Act has no effect and the district court's injunction is vacated.
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