This Note addresses an emerging conflict concerning federal subject matter jurisdiction and international comity: can and should federal courts issue post-satisfaction anti-foreign-suit injunctions? The Eighth Circuit has held that a federal court no longer possesses subject matter jurisdiction to grant anti-suit injunctions after a party has satisfied judgment. The Eighth Circuit also held that a post-satisfaction anti-foreign-suit injunction would be inconsistent with international comity. In contrast, the Second Circuit has held that a federal court possesses continuing subject matter jurisdiction to grant anti-foreign-suit injunctions after the satisfaction of judgment and that such an injunction does not violate international comity.
This Note argues that, as a general matter, federal courts no longer possess subject matter jurisdiction to grant anti-suit injunctions after the satisfaction of judgment. It also contends that post-satisfaction anti-foreign-suit injunctions are ordinarily inconsistent with international comity and concludes that the President and Congress, not the courts, are better equipped to resolve legal disputes implicating United States foreign relations.