Chick Kam Choo v. Exxon Corp.

Leong Chong was killed in Singapore while working on a ship owned by Esso Tankers, Inc., a subsidiary of Exxon Corporation (collectively, Exxon) (defendants). Chick Kam Choo (plaintiff), Chong’s widow and a resident of Singapore, filed a lawsuit against Exxon in the United States District Court for the Southern District of Texas, alleging violations of federal statutes, federal maritime law, and Texas law. Exxon moved for summary judgment, arguing that Singapore law rather than United States law governed. Exxon also moved to dismiss the case under the doctrine of forum non conveniens, arguing that the district court was an inconvenient forum. The district court held that Singapore law governed and dismissed the case on forum non conveniens grounds. Choo filed a lawsuit in Texas state court against Exxon, alleging violations of Texas state law and Singapore law. In response, Exxon filed a lawsuit in federal district court to enjoin Choo’s state court action. Choo moved to dismiss Exxon’s case, arguing that the federal Anti-Injunction Act prohibited the district court from enjoining her state court action. Exxon opposed the motion, claiming that the relitigation exception to the federal Anti-Injunction Act applied to the case because the federal district court had previously held that Texas was an inconvenient forum for Choo’s claims. The district court enjoined Choo’s state court action. The court of appeals affirmed the district court, reasoning that federal forum non conveniens decisions preempted state forum non conveniens decisions. This meant that the federal district court had already held that Texas was an inconvenient forum for Choo’s claims. Therefore, the relitigation exception to the Anti-Injunction Act applied. Choo appealed. The United States Supreme Court granted certiorari.