Smith v. Bayer Corp.

Facts of the Case

Petitioner consumers sued respondent pharmaceutical company in the state court regarding a drug. Respondent moved in federal district court for an injunction ordering the state court not to consider the motion for class certification filed by the petitioners. The respondent had persuaded the same federal district court to deny a similar class-certification motion that had been filed against respondent by a different plaintiff. Thereafter, the federal district court enjoined the state court from hearing a certification motion under the relitigation exception to the Anti-Injunction Act, 28 U.S.C.S. § 2283. The appellate court affirmed. The Supreme Court of the United States granted certiorari.


Did a lower court erroneously prevent a group of plaintiffs from proceeding with a class-action lawsuit over a cholesterol-lowering drug that was removed from the market in 2001?


Yes. The Supreme Court reversed the lower court’s opinion in a unanimous decision by Justice Elena Kagan. In enjoining the state court from considering Smith’s class certification request, the federal court exceeded its authority under the ‘relitigation exception’ to the Act, Kagan wrote.

Case Information

  • Citation: 564 US _ (2011)
  • Granted: Sep 28, 2010
  • Argued: Jan 18, 2011
  • Decided Jun 16, 2011