Ninth Circuit vacates anti-suit injunction

In a lengthy 2-1 decision, the U.S. Court of Appeals for the Ninth Circuit vacated an anti-suit injunction issued by a federal court in Oregon that had barred a state court in Minnesota from entering part of a jury award there. Sandpiper Village Condominium Assoc. v. Louisiana-Pacific Corp. The Oregon court had overseen the settlement of a 1996 nationwide class action concerning defects with defendant's exterior siding product; by 2003, L-P had paid out $509 million to 142,000 claimants nationwide. In 2002, a Minnesota state jury awarded Lester, a Minnesota builder not a member of the settlement class $29.6 million in damages for siding failure. The Oregon class action court then barred the Minnesota court from entering part of this judgment pursuant to its authority under the All-Writs Act, concluding that it fit into two exceptions in the Anti-Injunction Act. The Ninth Circuit reversed, holding that the injunction fit neither exception because it was not necessary to protect the Oregon court's jurisdiction nor necessary to preclude relitigation. Judge Richard Clifton authored the decision, with Judge Barry Silverman concurring. Judge Stephen Reinhardt wrote a lengthy dissent noting the tension between Congress' extension of federal class action jurisdiction and this decision's limitation on the capacity of federal courts to protect their class action outcomes.