Betker

This case arises from the settlement of a complex of securities fraud cases involving the sale of municipal bonds for renovation and construction of health care facilities. The litigation was commonly referred to as the In re Heritage Bond Litigation. The district court ultimately approved multiple settlement agreements between different plaintiffs and defendants pursuant to Federal Rule of Civil Procedure 23 (“Rule 23”), California Code of Civil Procedure section 877.6 (“section 877.6”), and the Private Securities Litigation Reform Act of 1995 (“PSLRA”), 15 U.S.C. § 78u-4. In approving the settlements, the district court issued five bar orders that barred non-settling defendants from bringing against settling defendants any future claims “arising out of or related to ... any of the transactions or occurrences alleged.” Appellant Bruce Talley (“Talley”), a non-settling defendant, objected to the scope of the bar orders on the ground that he sought to pursue independent state law claims against several of the settling defendants.

The district court, applying the “interrelatedness” test from Wisconsin Investment Board v. Ruttenberg, 300 F.Supp.2d 1210 (N.D.Ala.2004) (following In…