Rosner v. United States

After World War II, the United States misappropriated property that had been seized from Hungarian Jews by the pro-Nazi Hungarian government. Seeking compensation, some Hungarian Jews brought a class action against the United States in federal district court in Florida. Under the settlement (dubbed the Hungarian Gold Train settlement), the United States established a fund from which eligible individuals received up to $2,500 per year for social services and humanitarian relief. The annual amounts were determined by the agencies that administered the program. The final order approving the settlement stated that the district court retained exclusive and continuing jurisdiction to enforce the order’s obligations, including the settlement agreement’s performance and enforcement. Robert Langermann (plaintiff) was a class member. The agencies responsible for administering Langermann’s benefits required financial information and a home visit. Objecting to the agencies’ procedures and to having received less than $2,500 in some years, Langermann sought to hold the agencies in contempt for violating his privacy right and the settlement’s allocation plan. The court denied Langermann’s motion. Lead class counsel refused to appeal, and the court did not act on Langermann’s reconsideration request. Langermann sued the judge, lead class counsel, and the agencies (defendants) in federal district court in Nevada, alleging they conspired to deprive him of his right to benefits. Upon lead class counsel’s motion, the Florida district court enjoined Langermann from prosecuting the Nevada suit. Langermann argued on appeal that the court lacked jurisdiction to consider the injunction motion, the All Writs Act did not permit the court to enjoin the Nevada litigation, and the Anti-Injunction Act barred the injunction.