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A Connecticut federal court had the authority to issue an injunction stopping a man from repeatedly relitigating in another jurisdiction his claim that his parental rights were invalidly terminated in Texas, the 2d U.S. Circuit Court of Appeals has ruled. Smith v. Woosley, No. 03-9198. Addressing the “relitigation exception” to the Anti-Injunction Act, the 2d Circuit upheld, with slight modifications, a federal judge’s grant of an injunction in favor of a couple whose adoption of a baby was challenged in three states by the biological father. Paul David Woosley, the father of Kyle Smith, waived his parental rights in 1992. Texas courts later issued decrees terminating his parental rights and declaring David and Kimberly Smith as Kyle’s adoptive parents. Woosley’s attempts to have the decrees set aside were rejected by a Texas state court. He then sued in Pennsylvania federal court, claiming that his parental rights had been invalidly terminated. The court dismissed the case in 1998 as time-barred. Woosley filed suit in Connecticut state court in 2000, again challenging the Texas decrees. The Smiths filed a suit of their own in Connecticut federal court seeking damages for vexatious litigation and infliction of emotional distress. They also sought an injunction, which was granted by Judge Alvin W. Thompson, on the ground that it was “necessary and appropriate to protect the collateral estoppel effect of the judgment” of the Pennsylvania federal court. The Anti-Injunction Act, 28 U.S.C. 2283, prevents federal district courts from staying state court proceedings “except as expressly authorized by an Act of Congress, or where necessary in aid of its jurisdiction.” Judge Jon O. Newman of the 2d Circuit said that it is “well settled that the Act applies to injunctions that prohibit a person from litigating in a state court, as well as injunctions that directly stay proceedings in a state court.” The exception to the prohibition, which allows a court to act to protect “its judgments,” Newman said, “is naturally read to mean the same court that is authorized to issue an injunction.” But it is an open question on whether the section prevents one federal court from issuing an injunction to protect the judgment of another federal court. “However, the purpose of the relitigation exception-precluding relitigation in state courts of issues determined by a federal court-appears to be better served by allowing a district court that has subject matter and personal jurisdiction to issue an injunction that protects the judgment of another federal court than by forcing the litigants to a likely inconvenient forum for an identical result,” Newman said. “Fortunately, we need not rule definitively on the matter because two other factors weigh heavily in favor of affirming the injunction,” he said. First, even if the relitigation exception only allowed courts to issue injunctions to protect their own judgments, “that limitation seems more akin to a venue limitation than to a limit on subject matter jurisdiction,” and Woosley “failed to object to the court’s authority” in Connecticut. Second, � 2283 “is a statute that regulates the equity power of a district court, and in the pending case, the equities overwhelmingly favor the issuance of an injunction to bar further relitigation of the Texas court decrees.” Newman said that the determination of the preclusive effect of the statute of limitations ruling the federal district court in Pennsylvania, together with the U.S. Supreme Court’s “admonition” that the relitigation exception “permits protection against relitigation only of what a prior federal court has already decided,” guides the degree of protection the Connecticut federal court was entitled to give the Pennsylvania court. The circuit went on to modify the injunction to allow Woosley to seek relief in Connecticut if he can find a jurisdiction in which a limitations period remains open, could obtain personal jurisdiction over the applicants and was entitled to challenge the Texas decrees. – Mark Hamblett

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