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Smith v. Bayer
(U.S. Supreme Court)
Class action certification procedures
The Supreme Court decided that a class action suit that has been rejected in federal court, in part because the plaintiffs did not prove sufficient injury, can be relitigated in state court using state rules. The Court ruled that the federal Anti-Injunction Act generally prohibits federal courts from enjoining state court proceedings, and an exception for re-litigating cases is to be narrowly construed. A state court proceeding may continue if the issue previously decided by the federal court is not the same as the one before the state court, and The Court ruled that West Virginia rules on class certification are a bit different from federal rules and may be relitigated under state law. In addition, the plaintiff was not a party in the earlier case. The case involves alleged economic loss by plaintiffs who bought the cholesterol-lowering medication Baycol.
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