The Second Circuit recently affirmed a district court’s refusal to enjoin an arbitration proceeding under the All Writs Act. The parties to the dispute had been involved in a prior arbitration that resulted in an award confirmed by the district court. While the confirmation judgment was on appeal, one of the parties instituted a second arbitration raising claims similar to those asserted in the first arbitration. The respondent, Citigroup, Inc., filed suit in the Southern District of New York, arguing that the All Writs Act should be applied to enjoin the second arbitration because the second arbitration amounted to an “assault” on the prior federal judgment confirming the first award. The district court rejected Citigroup’s argument, dismissed the federal court action, and compelled arbitration. The Second Circuit affirmed, holding that the FAA’s framework favoring the submission of disputes to arbitration precludes use of the All Writs Act to enjoin a subsequent arbitration of claims that one party asserts are barred by the prior arbitration. In reaching this decision, the Second Circuit noted that the prior federal judgment did not involve consideration of the merits of the underlying claims, but rather merely confirmed an arbitration award through a limited review. The Second Circuit concluded that a federal court’s interest in protecting the integrity of such a prior judgment does not authorize use of the All Writs Act. Citigroup, Inc. v. Abu Dhabi Inv. Auth., No. 13-4825-CV, 2015 WL 161745 (2d Cir. Jan. 14, 2015).