DENNIS ADKINS, et al., Plaintiffs-Appellees, and CONNIE CURTS, Intervening Plaintiff-Appellant, v. NESTLÉ PURINA PETCARE COMPANY and WAGGIN' TRAIN, LLC, Defendants-Appellees., 779 F.3d 481

Summary

HOLDINGS: [1]-The district court failed to identify the appropriate legal standard and to make the required findings of law and fact under Fed. R. Civ. P. 65(d)(1)(A) in issuing a preliminary injunction against litigation in any other forum, which apparently was prompted by concerns that a state decision might imperil a settlement in the federal case; [2]-The injunction was improper under the Anti-Injunction Act, 28 U.S.C.S. § 2283, because the likelihood of having to adjudicate the suit on the merits after the failure of settlement negotiations did not undermine the nature or extent of the federal court's jurisdiction, and absent any contention that there might be a significant prospect of inconsistent injunctions affecting future conduct, an injunction to prevent the state court from reaching a decision first was not necessary in aid of the federal court's jurisdiction.