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Tooele Cty. v. United States, — F.3d —, 2016 WL 17434273 (10th Cir. May 3, 2016)

May 3, 2016

The court considered whether the Anti-Injunction Act prohibits enjoining parties from pursuing a state-court action challenging state officials’ authority to pursue a federal quiet-title action. The court limited the statutory exception for cases where an injunction is “necessary in aid of [the federal district court’s] jurisdiction” to cases where both the federal and state are in rem or quasi in rem. Because the parties in the state case sought an adjudication of state officials’ legal authority, as opposed to an adjudication of property interests, the exception did not apply.