Atlantic Coast Line R.R. v. Brotherhood of Locomotive Engineers

In Atlantic Coast Line R.R. v. Brotherhood of Locomotive Engineers, 398 U.S. 281 , 287 (1970), the district court attempted to circumvent the Anti-Injunction Act, 28 U.S.C. 2283, by enjoining the party who prevailed in state court from giving effect to or availing itself of the benefits of the state-court order. The Supreme Court reversed, noting that it is settled that the prohibition of 2283 cannot be evaded by addressing the order to the parties or prohibiting utilization of the results of a completed state proceeding. The Court rejected the argument that "a federal court may enjoin state court proceedings even if that action cannot be justified by any of the three exceptions." 398 U.S. at 286-87, 90 S.Ct. 1739. The Court held, instead, that the Anti-Injunction Act "is an absolute prohibition against enjoining state court proceedings, unless the injunction falls within one of three specifically defined exceptions." Id. at 286, 90 S.Ct. 1739. "Proceedings in state courts should normally be allowed to continue unimpaired by intervention of the lower federal courts, with relief from error, if any, through the state appellate courts and ultimately this Court." Id. at 287, 90 S.Ct. 1739.