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Supreme Court: All Writs Act No Basis for Removing State Court Lawsuit - Syngenta Crop Protection v. Henson, 123 S. Ct. 366 (Nov. 5, 2002)

Decision: http://www.supremecourtus.gov/opinions/02pdf/01-757.pdf
AAJ's Amicus Curiae Brief: Syngenta Crop Protection v. Henson

[Posted December 5, 2002]

This case began as a class action by farmers in Louisiana for illness caused by Ciba-Geigy insecticide. The Louisiana farmers then intervened in a separate class action in federal district court in Alabama. That case ended in a settlement. Unhappy with that result, the Louisiana farmers resumed their action in Louisiana state court, which ruled that the settlement did not resolve all their claims. Defendant moved to bring the case back into federal court, asserting jurisdiction under the All Writs Act, which provides that federal courts "may issue all writs necessary or appropriate in aid of their respective jurisdictions."

The case was removed to Louisiana federal court, which transferred it to the Alabama federal court, which dismissed the action as barred by the settlement. The Eleventh Circuit reversed, aligning itself with those circuits narrowly interpreting the All Writs Act. The Supreme Court granted cert to resolve the circuit split.

AAJ as amicus argued that the All Writs Act does not itself provide a basis for federal jurisdiction. The Act should be narrowly construed to preserve the independence of state court judicial systems. State courts are competent to determine the preclusive effect of a prior settlement in federal court, and there is no necessity to expand federal jurisdiction at the expense of state courts.

Chief Justice Rehnquist, writing for a unanimous Court, affirmed. The Court held that the All Writs Act provides no independent basis for removal jurisdiction. The Court emphasized that "a suit commenced in a state court must remain there until cause is shown for its transfer under some act of Congress."

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