Supreme Court Reverses Federal Court Injunction of State Court Class Action

Summary: On June 16, 2011, the Supreme Court unanimously held that a federal court, which had denied a class certification motion, exceeded its authority in entering an injunction against a parallel state court class action. See Smith v. Bayer Corp., No. 09-1205 (U.S. June 16, 2011). The Court’s decision has significant implications for class certification defense. The attached Client Alert analyzes the Court’s decision and highlights the need for class action defendants to make every attempt to employ the Class Action Fairness Act to consolidate proposed class actions in a single forum.