Summary

Mahlon Pitney Essanay Film Manufacturing Company v…

But when the litigation in the state court has come to an end and final judgment has been obtained, the question whether the successful party should in equity be debarred from enforcing the judgment, either because of his fraud or for the want of due process of law in acquiring jurisdiction, is a different question, which may be passed upon by a federal court with out the conflict which it was the purpose of the act of 1793 to avoid.
Source: Wikisource

Mahlon Pitney Essanay Film Manufacturing Company v…

In this court, as in the courts below, appellant's chief reliance is upon Simon v. Southern Railway, 236 U.S. 115, 35 Sup. Ct. 255, 59 L. Ed. 492. Without intimating that in other respects the cases are parallel, it is a sufficient ground of distinction that this is an attempt to use the process of the federal court to restrain further prosecution of an action still pending in a state court, while that cited was a case of enjoining a successful litigant from enforcing a final judgment of a state court held void because procured without due process.
Source: Wikisource

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