DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
192932P.pdf 05/28/2021 John Petitta v. 3M Company
U.S. Court of Appeals Case No: 19-2932
U.S. District Court for the District of Minnesota
[PUBLISHED] [Kelly, Author, with Gruender and Grasz, Circuit Judges]
Civil Case - Products Liability - Injunction. District court permanently
enjoined litigation in Texas state court of claims parties had previously
agreed to dismiss with prejudice in multidistrict litigation in federal
court, concluding dismissal had preclusive effect. Petitta appeals,
arguing the religation exception to the Anti-Injunction Act does not
apply. As to the choice of law, considering this was an MDL case sitting
in diversity and Petitta filed in Minnesota pursuant to the standing
order, Texas choice-of-law applies and Texas substantive law governs.
Applying Texas law, the dismissal with prejudice was simply an agreement
to dismiss, was not a settlement of the MDL claims, and did not resolve
claims on the merits. Thus, the dismissal "with prejudice" was not a final
judgment on the merits and the claims in Texas state court were not
precluded under Texas law. The relitigation exception to the
Anti-Injunction Act has no effect and the district court's injunction is
vacated.