Chick Kam Choo v. Exxon Corporation

Supreme Court of the United States · 1988 · Federal Courts

Federal CourtsAnti-Injunction ActRelitigation ExceptionForum Non ConveniensPreclusion28 U.S.C. § 2283Anti-Injunction Actrelitigation exception

Facts

Petitioner's husband, a Singapore resident, was killed in Singapore while working on a ship owned by respondents. Petitioner sued in federal district court asserting federal maritime and Texas wrongful death theories, and the district court held the Jones Act and DOHSA inapplicable, held United States maritime law should not apply, concluded Singapore law controlled, and dismissed the rest of the case on forum non conveniens grounds subject to respondents' submission to Singapore jurisdiction. Petitioner then sued in Texas state court and, after dismissing her federal claims, pursued only Texas state law and Singapore law claims. Respondents returned to federal court and obtained an injunction barring petitioner from pursuing any claims arising from the death in state court.

Issue

Whether the Anti-Injunction Act's relitigation exception allowed the federal district court to enjoin petitioner's Texas state-court action. More specifically, the question was whether the issues implicated by petitioner's Singapore-law and Texas-law claims had actually been decided in the prior federal action so that an injunction was necessary to protect or effectuate the federal judgment.

Rule

Under the Anti-Injunction Act, a federal court may enjoin state proceedings under the relitigation exception only to prevent litigation of claims or issues that were actually presented to and decided by the federal court. This prerequisite is strict and narrow: courts must look to the precise record and the actual terms of the earlier federal judgment, not to post hoc views of what the judgment was intended to decide. A federal court may not enjoin state proceedings merely because they raise a federal issue or even a preemption issue unless that issue itself was actually litigated and decided in the prior federal case.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nadia Flores sued Harbor Crest Shipping in federal court in Miami over an accident in Belize. The district court dismissed on federal forum non conveniens grounds after applying federal convenience factors, but it did not discuss whether Florida state courts could hear the case under their own procedural standards. Flores then filed the same foreign-law negligence claim in Florida state court.

May the federal court enjoin the Florida action under the relitigation exception?

Explanation. The relitigation exception is narrow and reaches only claims or issues actually presented to and decided by the federal court. A federal forum non conveniens dismissal does not itself determine whether a state court, applying its own standards, is an appropriate forum. So the federal court may not enjoin the state proceeding on that basis alone.