Randtron

Two issues are presented in this appeal: 1) Whether the Anti-Injunction Act barred the district court from issuing a declaratory judgment precluding the California Superior Court from considering Randtron’s res judicata defense; and 2) whether the district court erred in ruling that the Consent Decree barred Randtron from asserting a counterclaim for contribution against Lodi in a separate state court lawsuit in which Lodi attempted to impose liability on Randtron above and beyond the liability asserted and settled in the federal court lawsuit.

BACKGROUND

In April 1998, the State of California and Lodi, a California municipality (collectively referred to as “Lodi”), brought a federal environmental cause of action against Randtron, a dissolved California corporation, 1 for soil and groundwater contamination. The complaint alleged causes of action under the Resource Conservation and Recovery Act, the Comprehensive Environmental Response, Compensation and Liability Act and the Lodi Comprehensive Municipal Environmental Response and Liability Ordinance (“MERLO”). When Randtron was an operating business, it had insurance policies with at least two companies — Employers…