FRENCH, TRUSTEE,
v.
HAY
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A federal court in equity granted an injunction to prevent enforcement of a decree that a lower federal court had annulled, protecting the appellee from being compelled to satisfy a judgment that had been invalidated. The Supreme Court affirmed, holding that once a federal court acquires jurisdiction over a case, it retains exclusive jurisdiction to grant all necessary relief to prevent inconsistent outcomes, and the statutory prohibition on federal injunctions against state court proceedings does not apply where the federal court's prior jurisdiction encompasses the matter.
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Mr. Justice SWAYNE delivered the opinion of the court.
A stronger equity can hardly exist than that which is developed in favor of the appellee in the case before us.
The order of the court below, annulling the decree upon which the suit at law in Pennsylvania was founded, was fatal to that action, and entitled Hay to a perpetual injunction, without reference to the final result of the prior case.
This bill is not an original one. It is auxiliary and dependent in its character, as much so as if it were a bill of review.‡ The court having jurisdiction in personam, had power to require the defendant to do or to refrain from doing anything beyond the limits of its territorial jurisdiction which it might have required to be done or omitted within the limits of such territory.* Having the possession and jurisdiction of the ease, that jurisdiction embraced everything in the case, and every question arising which could be determined in it until it reached its termination and the jurisdiction was exhausted. While the jurisdiction lasted it was exclusive, and could not be trenched upon by any Other tribunal.† The court below might, upon a cross-bill, and, perhaps, upon motion, have given the relief which was given by the interlocutory and the final decree in the case before us.
If it could not be given in this ease the result would have shown the existence of a great defect in our Federal jurisprudence, and have been a reproach upon the administration of justice. In that event the payment of the annulled decree may be enforced in Pennsylvania, and Hay, notwithstanding the final decree in that ease, and in this case, would find himself in exactly the same situation he would have been if those decrees had been against him instead of being in bis favor. They would be nullities as regards any protection they could have given him. Instead of terminating the strife between him and his adversary, they would leave him under the necessity of engaging in a new conflict elsewhere. This would be contrary to the plainest principles of reason and justice.
The prohibition in the Judiciary Act against the granting of injunctions by the coui’ts of the United States touching proceedings in State courts has no application here. The prior jurisdiction of the court below took the case out of the operation of that provision.
If the State courts should persist in proceeding — a thing not to be expected — the wrong will be on the part of those tribunals and not of the court below.
Decree affirmed.
‡
Logan v. Patrick, 5 Cranch, 288; Dunn v. Clark, 8 Peters, 1; Dunlap v. Stetson, 4 Mason, 349, 360; Clark v. Mathewson, 12 Peters, 164.
*
Watts v. Waddle, 6 Peters, 391; Lewis v. Darling, 1 Howard, 1.
†
Hagan v. Lucas, 10 Peters, 400; Taylor v. Carryl, 20 Howard, 484; Freeman v. How, 24 Id. 450; Taylor v. Tainter, 16 Wallace, 370.
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Gen. Elec. Cap. Corp. v. Advance Petroleum, Inc., 660 So. 2d 1139 (Fla. 3d DCA 1995)…o require the defendant to do or to refrain from doing anything beyond the limits of its territorial jurisdiction which it might have required to be done or omitted within the limits of such territory.” French v. Hay, 89 U.S. (22 Wall.) 250, 252-53, 22 L.Ed. 857, 858 (1874). These authorities make clear that, although a court may not directly act upon real or personal property which lies beyond its borders, it may indirectly act on such property by its assertion of in personam jurisdiction over the defendan…
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O'Shea v. Littleton, 414 U.S. 488 (U.S. 1974)…l Act of 1942, 56 Stat. 33. See Porter v. Dicken, 328 U. S. 252, 255. (7) Legislation providing for the removal of litigation to federal courts and the simultaneous cessation of state court proceedings, 28 U. S. C. § 1446 (e). See French v. Hay, 22 Wall. 250. [*513] This Court has also recognized the power of a federal court to stay proceedings in a state court to prevent relitigation of an issue already decided in a federal proceeding. See Supreme Tribe of Ben-Hur v. Cauble, 255 U. S. 356; Julian v. Ce…
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Mitchum v. Foster, 407 U.S. 225 (U.S. 1972)…Mich. L. Rev. 1145 (1932). As so amended, the- statute provided that state court proceedings could be enjoined “where such injunction may be authorized by any law relating to proceedings in bankruptcy.” Rev. Stat. § 720 (1874). See French v. Hay, 22 Wall. 250; Kline v. Burke Construction Co., 260 U. S.. 226. The federal' removal provisions, both .civil and criminal, 28 U. S. .C. §§ 1441-1450, provide that once a copy of the removal petition is filed with the clerk of the state court, the “State court^sha…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Clarke v. Mathewson, 12 Pet. 164 (U.S. 1838)
- Hagan v. Lucas, 10 Pet. 400 (U.S. 1836)
- Dunn v. Clarke, 8 Pet. 1 (U.S. 1834)
- Logan v. Patrick, 5 Cranch 288 (U.S. 1809)