In Adkins v. Nestle Purina PetCare Co., No. 143436 (7th Cir. Mar. 2, 2015), the district court preliminarily approved the settlement of a nationwide class action, and enjoined class members from prosecuting litigation about the same subject in any other forum. This had the effect of enjoining the imminent trial of a state class action in Missouri. The Missouri class plaintiff objected and, after being unsuccessful in the district court, appealed. The settling parties argued on appeal that the injunction was necessary in aid of the district court’s jurisdiction. The Seventh Circuit found no support for this position. It held jurisdiction means “adjudicatory competence,” and does not encompass procedural or substantive rules that decide how cases are to be resolved. While the Missouri litigation could imperil the settlement, it would not deprive the district court of adjudicatory competence. As a result, the Anti-Injunction Act precludes an injunction until the federal case reaches a final decision. The court added that parallel state and federal litigation is common, and recognized that while the first case to reach final decision can affect the others, that potential effect does not justify a pre-judgment injunction.