Edleson, et al. v. American Home Shield Corp., et al.

This appeal involved a fundamental misunderstanding about the enforcement of an injunction. The district court approved a settlement between defendant and a national class represented by plaintiffs, as part of its judgment, enjoined permanently "anyone claiming... for the benefit of" members of the class for prosecuting released claims. Movants opted out of the settlement of that class action, but continued to prosecute a putative class action against defendant in a California court. Instead of moving the district court to enforce its extant injunction, defendant then moved the district court to enter another injunction to bar movants from prosecuting their putative class action in the California court, under the All Writs Act, 28 U.S.C. 2283. The district court granted that motion and entered a second injunction, which movants now challenge on appeal. The court held that because the district court failed to comply with "equity's time-honored procedures" to enforce an injunction, the second injunction against movants was vacated and remanded for further proceedings.