In 1998, plaintiffs sued Computer Associates alleging violations of the federal securities laws. After the parties settled the case in 2003, the district court conducted a fairness hearing, approved the settlement, and found that plaintiffs’ counsel were entitled to substantial fees. After the settlement, additional revelations concerning Computer Associates became public and a group of class members (“Wyly plaintiffs”) brought a Rule 60(b) motion to reopen the case. Class counsel declined to join the motion, which the district court denied, finding plaintiffs had failed to present any new evidence. The Wyly plaintiffs then brought a malpractice action against class counsel, who asked the district court to enjoin that state court action. The district court granted the injunction, and the Second Circuit affirmed. Wyly v. Weiss,697 F.3d 131 (2d Cir. 2012) (No. 10-4785). The Court of Appeals focused on whether it had jurisdiction to enter an injunction, and declined to exercise jurisdiction under the “in aid of jurisdiction exception” to the Anti-Injunction Act. The court found that this exception is generally reserved for state court actions in rem. While in limited circumstances it has been used to enter injunctive relief in personam, the court found the circumstances of this case did not justify exercise of that jurisdiction. The court found, however, that the injunction was appropriate under the Anti-Injunction Act’s re-litigation exception. In approving the settlement, the district court had necessarily found that class counsel’s conduct was reasonable and adequate. That prior finding precluded a determination in the malpractice case that counsel had behaved deficiently. As a result, the new allegations were an impermissible collateral attack on the prior district court’s findings that the counsel’s performance was adequate. The court also rejected the argument that the current objectors were not represented in the prior action. They were members of the settlement class, and thus bound by the final order and the Rule 60(b) order.