Appeal from the United States District Courtfor the District of NevadaLloyd D. George, District Judge, PresidingArgued and SubmittedNovember 2, 1998--San Francisco, CaliforniaFiled April 8, 1999Before: Betty B. Fletcher, A. Wallace Tashima, andM. Margaret McKeown, Circuit Judges.Opinion by Judge A. Wallace Tashima
_____________________________COUNSEL Richard G. Campbell, Jr., Campbell & Stone, Reno, Nevada,for the petitioner-appellant.Frankie Sue Del Papa, Attorney General of Nevada, David C.Creekman, Deputy Attorney General, Carson City, Nevada,for the respondent-appellee.Lois J. Schiffer, Assistant Attorney General, Stephen M. Mac-farlane, Trial Attorney, Environment & Natural ResourcesDivision, U.S. Department of Justice, Sacramento, California,for the plaintiff-appellee.Steven D. King, Assistant City Attorney, Fallon, Nevada, foramicus curiae City of Fallon.Gordon H. DePaoli, Woodburn & Wedge, Reno, Nevada, foramicus curiae Sierra Pacific Power Co.Robert S. Pelcyger, Fredericks, Pelcyger, Hester & White,L.L.C., Louisville, Colorado, for amicus curiae Pyramid LakePaiute Tribe of Indians.Donald L. Christensen, Deputy City Attorney, Reno, Nevada,for amici curiae Cities of Reno and Sparks, Nevada.
_____________________________OPINION TASHIMA, Circuit Judge:Churchill County appealed to a Nevada state court the deci-sion of the Nevada State Engineer, R. Michael Turnipseed,granting a water rights transfer application to the UnitedStates Fish and Wildlife Service. The United States DistrictCourt for the District of Nevada enjoined the state court pro-ceeding because the state proceeding interfered with the dis-trict court's exclusive jurisdiction to hear appeals regardingthe water rights at issue, rights that had been originally adju-dicated by the district court. Churchill County appeals, con-tending that the district court erred in issuing the injunction.We have jurisdiction pursuant to 28 U.S.C. S 1291, and weaffirm.I.At the turn of this century, the Secretary of the Interior, act-ing pursuant to congressional authorization, withdrew fromthe public domain a large tract of land in western Nevada.This land became the Newlands Reclamation Project, a proj-ect diverting and storing water from the Truckee and CarsonRivers in a reservoir behind Lahontan Dam and distributingit downstream by means of canals for irrigation and relateduses. See Nevada v. United States,
463 U.S. 110
, 113-18(1983) (giving overview of history and geography of theTruckee River and Carson River basins). In 1913, the UnitedStates began quiet title proceedings in the United States Dis-trict Court for the District of Nevada to adjudicate the waterrights of all users, including the Newlands Reclamation Proj-ect, to the Truckee River. A final decree was entered in 1944,known as the Orr Ditch Decree. The United States brought asimilar proceeding for the Carson River in the same federalcourt in 1925, which resulted in 1980 in the Alpine Decree.This appeal involves water rights owned by the United States,specifically, the United States Fish and Wildlife Service("Fish and Wildlife Service"), in the Newlands ReclamationProject in Churchill County, Nevada. Applications to changethe place of diversion or the manner or place of use of waterrights adjudicated under these Decrees are directed in the firstinstance to the State Engineer of Nevada ("State Engineer").See United States v. Orr Water Ditch Co., 914 F.2d 1302,1311 (9th Cir. 1990); United States v. Alpine Land & Reser-voir Co., 697 F.2d 851, 860 (9th Cir. 1983) ("Alpine I").On April 4, 1996, the Fish and Wildlife Service filed twoapplications with the State Engineer to change the place andmanner of use of the water rights it had purchased from otherusers and that had been adjudicated under the Alpine and OrrDitch Decrees. Under the Fish and Wildlife Service's applica-tion, the water was to be transferred from the Newlands Rec-lamation Project to the Lahontan Valley Wetlands and usedfor recreation, wildlife, and maintaining the wetlands. Chur-chill County filed a protest to each application with the StateEngineer, asserting that the transfer of water would depleteChurchill County's groundwater supply, harm its tax base,and create a dust hazard. On October 30, 1996, the State Engi-neer conducted a public hearing and found that the transferwould result in little if any effect on the groundwater supply,negligible tax consequences, and no threat of a dust hazard.Accordingly, the State Engineer granted one of the Fish andWildlife Service's applications.1In November 1996, Churchill County filed an appeal of theState Engineer's ruling in the Third Judicial District Court ofthe State of Nevada. The State Engineer filed a motion to dis-miss for lack of jurisdiction, which the court denied. TheNevada court narrowly construed the relevant federal courtprecedent, which held that the federal district court exercisesappellate jurisdiction over decisions of the State Engineer thatinvolve federally decreed water rights. The state court furtherheld that Nevada Revised Statute S 533.450 2 applies only towater rights decrees entered by state courts.On August 11, 1997, the State Engineer filed a motion inthe United States District Court for the District of Nevadaasking the court to enjoin, pursuant to 28 U.S.C.SS 1651 and2283, further proceedings in the state court. The UnitedStates, in its capacity as plaintiff in the Alpine and Orr Ditchactions, filed a brief in support of the State Engineer's motion.While the motion was pending, Churchill County filed amotion in the state court to enjoin the federal proceeding,which the state court granted. On September 17, 1997, inidentical orders under the Alpine and Orr Ditch Decrees, thefederal district court issued its own injunction. 3Churchill County contends that the district court erred inenjoining the state proceeding because the district court doesnot have exclusive jurisdiction over all of the State Engineer'srulings regarding waters of the Carson and Truckee Rivers.According to Churchill County, the district court's jurisdic-tion is limited to decisions that implicate federal interests inthe operation of the Newlands Reclamation Project. ChurchillCounty also argues that the district court improperly reviewedthe decision of the Nevada state court.II.We review the existence of subject matter jurisdiction denovo. See Galt G/S v. JSS Scandinavia, 142 F.3d 1150, 1153(9th Cir. 1998). The question of whether the district courtcould enjoin the state court proceeding under the Anti-Injunction Act is also reviewed de novo. See Quackenbush v.Allstate Ins. Co., 121 F.3d 1372, 1377 (9th Cir. 1997). How-ever, the district court's decision to issue an injunction thatcomes within an exception to the Act is reviewed for an abuseof discretion. See id. "A district court abuses its discretionwhen it rests its conclusions on clearly erroneous factual find-ings or on incorrect legal standards." Id. III.A. JURISDICTION[1] Churchill County argues that the district court did nothave jurisdiction to enjoin the state court proceeding. We dis-agree. We conclude that the district court's jurisdiction overdisputes arising under the Alpine and Orr Ditch Decrees isboth continuing and exclusive.1. Continuing Jurisdiction[2] We have consistently interpreted both the Alpine andOrr Ditch Decrees to provide for federal district court reviewof decisions of the State Engineer regarding applications tochange the place of diversion or manner or place of use ofwater rights derived from the Alpine and Orr Ditch Decrees.The Alpine Decree expressly provides the district courtwith continuing jurisdiction over transfer applications: Applications for changes in the place of diversion, place of use or manner of use as to Nevada shall be directed to the State Engineer. Any person feeling himself aggrieved by any order or decision of the State Engineer on these matters may appeal that decision or order to this Court.(Emphasis added.)[3] This jurisdictional arrangement has been repeatedlyupheld. See United States v. Alpine Land & Reservoir Co.,878 F.2d 1217, 1219 n.2 (9th Cir. 1989) ("Alpine II")("Pursuant to the Alpine decree, the federal district court actsas an appellate court for decisions of the state Engineer.");Alpine I, 697 F.2d at 858; United States v. Alpine Land &Reservoir Co., 919 F. Supp. 1470, 1474 (D. Nev. 1996)("Aqueduct I").We have also interpreted the Orr Ditch Decree as providingfor continuing federal court jurisdiction over appeals fromdecisions of the State Engineer arising under that Decree. SeeOrr Water, 914 F.2d at 1308-09 & n.8. For change applica-tions, the Orr Ditch Decree instructs that [p]ersons whose rights are adjudicated hereby, their successors or assigns, shall be entitled to change in the manner provided by law the point of diversion and the place, means, manner or purpose of use of the waters to which they are so entitled or any part thereof, so far as they may do so without injury to the rights of other persons whose rights are fixed by this decree.(Emphasis added.)Although the Orr Ditch Decree does not expressly providefor federal district court review of the decisions of the StateEngineer, we have interpreted Nevada law, which providesfor jurisdiction of appeals from decisions of the State Engi-neer "in the court that entered the decree," as providing forfederal court review under the Orr Ditch Decree. Orr Water,914 F.2d at 1309 n.8 (quoting Nev. Rev. Stat. S 533.450(1))."Nevada law thus supports the system adopted by the federalcourts for appeals of Engineer decisions on federal-court-decreed water rights." Id.[4] We must determine whether the Fish and Wildlife Ser-vice's transfer application comes within the ambit of the juris-diction reserved in the Decrees. Churchill County argues thatthe transfer application does not because the jurisdictionretained by the Alpine Decree is "highly extraordinary" andlimited to cases involving federal interests in the NewlandsReclamation Project. Even assuming, arguendo, that thetransfer application at issue is unrelated to the United States'interest in the Newlands Reclamation Project,4 we rejectChurchill County's construction of the Decrees as too narrowin light of this circuit's precedent.[5] Churchill County's belief that federal court jurisdictionmust be based on the existence of a federal interest stemsfrom language in Alpine I and Alpine II . In particular, inAlpine I, this court stated that "[t]he United States is not con-cerned with the routine change application, but with the possi-bility that federal interests will be ignored by the NevadaState Engineer." Alpine I, 697 F.2d at 858. The Alpine I courtfound that district court appellate jurisdiction over transferapplications combined with the United States' ability to par-ticipate in proceedings before the State Engineer would"provide full vindication of the admitted federal interests inthe operation of federal reclamation projects." Id.; see alsoAlpine II, 878 F.2d at 1219 n.2 (quoting the same language).[6] Reasons for providing federal court jurisdiction, how-ever, are not the same as prerequisites for jurisdiction. TheAlpine I court addressed a dispute over whether applicationsfor change in the place of diversion or manner or place of useshould be directed to the State Engineer at all. The languagecited above responds to a concern that federal interests mightbe ignored. The Alpine I court did not say that federal courtjurisdiction would lie only when a federal interest is impli-cated. See also Aqueduct I, 919 F. Supp. at 1474 (statingbroadly that "this Court acts as an appellate court for deci-sions of the State Engineer with regard to federally decreedwater rights").[7] Churchill County also points to this court's statement inAlpine II that district court appellate jurisdiction over thedecisions of the State Engineer "is highly extraordinary."Alpine II, 878 F.2d at 1219 n.2. This language, however, doesnot mean that the district court may exercise jurisdiction onlyin rare instances. As evidenced by Alpine II's citations to thecases that gave rise to the Rooker-Feldman doctrine, Districtof Columbia Court of Appeals v. Feldman,
460 U.S. 462
(1983), and Rooker v. Fidelity Trust Co.,
263 U.S. 413
(1923), the Alpine II court was referring to the extraordinarynature of the district court's appellate jurisdiction under theAlpine Decree in relation to the doctrine that district courtsmay not exercise appellate jurisdiction over state court rul-ings. The Alpine II court expressly noted that, in spite of itsextraordinary nature, "[w]e specifically approved of this juris-dictional arrangement in [Alpine I]. " Alpine II, 878 F.2d at1219 n.2.[8] Thus, we find that the transfer application at issuecomes within the scope of jurisdiction intended by the Alpineand Orr Ditch Decrees.52. Exclusive Jurisdiction[9] Not only is the district court's jurisdiction continuing,it is exclusive. The district court held that it had exclusivejurisdiction because the Alpine and Orr Ditch matters are inrem actions and the district court gained jurisdiction over theres first. We find the district court's jurisdiction to be exclu-sive for two reasons.[10] First, the district court implicitly retained exclusivejurisdiction in the Alpine and Orr Ditch Decrees. As discussedabove, the Alpine Decree expressly reserves appellate juris-diction over decisions of the State Engineer for the districtcourt, and the Orr Ditch Decree has been similarly inter-preted. Neither the Decrees nor the cases interpreting theseDecrees mention concurrent jurisdiction with the Nevada statecourts. Furthermore, to construe these Decrees so that the dis-trict court does not retain exclusive jurisdiction would renderthe retention of jurisdiction a nullity. We have explained, inthe context of a settlement agreement, why retaining jurisdic-tion should be interpreted as retaining exclusive jurisdiction: The reason why exclusivity is inferred is that it would make no sense for the district court to retain jurisdiction to interpret and apply its own judgment to the future conduct contemplated by the judgment, yet have a state court construing what the federal court meant in the judgment. Such an arrangement would potentially frustrate the federal district court's purpose.Flanagan v. Arnaiz, 143 F.3d 540, 545 (9th Cir. 1998). TheFlanagan court, of course, also noted that it did "not mean toexclude the possibility that in some circumstances, the words,context, or subsequent order of the federal court might showthat retention of jurisdiction was not intended to beexclusive." Id. In light of the fact, however, that the Alpineand Orr Ditch Decrees were complex and comprehensivewater adjudications for which conflicting federal and stateconstructions would be entirely unworkable, the districtcourt's retention of jurisdiction was intended to be exclusive.[11] Second, the district court's jurisdiction is exclusivebecause its jurisdiction is best characterized as in rem juris-diction. Churchill County does not dispute the well-established proposition that the first court to gain jurisdictionover a res exercises exclusive jurisdiction over an actioninvolving that res. See, e.g., Kline v. Burke Constr. Co., 260U.S. 226, 229 (1922); Bergeron v. Loeb, 675 P.2d 397, 400(Nev. 1984). [State and federal courts] do not belong to the same system, so far as their jurisdiction is concurrent; and although they co-exist in the same space, they are independent, and have no common superior. They exercise jurisdiction, it is true, within the same terri- tory, but not in the same plane; and when one takes into its jurisdiction a specific thing, that res is as much withdrawn from the judicial power of the other, as if it had been carried physically into a dif- ferent territorial sovereignty. To attempt to seize it by a foreign process is futile and void.Kline,
260 U.S. at 229
-230 (quoting Covell v. Heyman, 111U.S. 176, 182 (1884)) (internal quotation marks omitted).Instead, Churchill County contends that the Nevada statecourt had exclusive jurisdiction because it asserted jurisdic-tion over the res before the district court, and therefore, it wasthe district court that was undermining the jurisdiction of thestate court. We are not persuaded.[12] The actions that resulted in the Orr Ditch and AlpineDecrees are sufficiently analogous to in rem actions to pro-vide the district court with exclusive jurisdiction. Nevada lawtreats water rights as real property. See In re Filippini, 202P.2d 535, 537 (Nev. 1949). Furthermore, the Supreme Courthas "recognized that actions seeking the allocation of wateressentially involve the disposition of property and are bestconducted in unified proceedings." Colorado River WaterConservation Dist. v. United States,
424 U.S. 800, 819
(1976)(treating the pending state court proceeding as an in remaction). The Supreme Court has noted that, although equitableactions to quiet title are technically in personam actions,"water adjudications are more in the nature of in remproceedings." Nevada v. United States,
463 U.S. 110
, 143-44(1983) ("everyone involved in Orr Ditch contemplated a com-prehensive adjudication of water rights"); see also Alpine I,697 F.2d at 853 (noting that "[t]his litigation is a virtuallycomprehensive adjudication") (internal quotation marks omit-ted) (citation omitted).[13] The Nevada state court could not have exercised inrem jurisdiction first because the federal district court hadalready asserted jurisdiction over the water rights in questionwhen it adjudicated the Alpine and Orr Ditch Decrees andbecause it continued to retain such jurisdiction. 6Therefore, because the district court retained exclusivejurisdiction and because the Decrees are properly analogizedto in rem proceedings, the district court exercises exclusivejurisdiction over actions arising under these Decrees.B. PROPRIETY OF THE INJUNCTIONChurchill County contends that the district court did notneed to enjoin the state court proceeding to protect what juris-diction it does have. We find that the district court did notabuse its discretion in doing so.1. The Anti-Injunction Act[14] The Anti-Injunction Act, 28 U.S.C. S 2283, prohibitsfederal courts from enjoining state court proceedings unlessone of three exceptions applies: "A court of the United Statesmay not grant an injunction to stay proceedings in a Statecourt except as expressly authorized by Act of Congress, orwhere necessary in aid of its jurisdiction, or to protect oreffectuate its judgments." 28 U.S.C. S 2283 (1994). Thesethree exceptions are to be construed narrowly, "resolv[ing]doubts in favor of letting the state action proceed."Quackenbush, 121 F.3d at 1378; see also Atlantic Coast LineR.R. v. Brotherhood of Locomotive Eng'rs,
398 U.S. 281
, 297(1970) ("Any doubts as to the propriety of a federal injunctionagainst state court proceedings should be resolved in favor ofpermitting the state courts to proceed in an orderly fashion tofinally determine the controversy."). "[T]he exceptions [to theAnti-Injunction Act] should not be enlarged by loose statutoryconstruction." Id.,
398 U.S. at 287
.[15] The district court relied on the second exception thatan injunction may issue "where necessary in aid of [thecourt's] jurisdiction." S 2283. The district court was correct todo so for two reasons.[16] First, it has long been held that the first court to exer-cise jurisdiction over real property is entitled to enjoin pro-ceedings in another court regarding that property. See, e.g.,Kline,
260 U.S. at 229
; Bergeron, 675 P.2d at 400. It is settled that where a federal court has first acquired jurisdiction of the subject-matter of a cause, it may enjoin the parties from proceeding in a state court of concurrent jurisdiction where the effect of the action would be to defeat or impair the jurisdic- tion of the federal court. Where the action is in rem the effect is to draw to the federal court the posses- sion or control, actual or potential, of the res , and the exercise by the state court of jurisdiction over the same res necessarily impairs, and may defeat, the jurisdiction of the federal court already attached.Kline,
260 U.S. at 229
. Therefore, by definition, the state pro-ceeding impairs the federal court's jurisdiction over this matter.7[17] Second, the "where necessary in aid of its jurisdiction"exception applies because the district court retained jurisdic-tion over the Orr Ditch and Alpine Decrees. In Flanagan, weheld that the district court's retention of jurisdiction in a set-tlement agreement was sufficient to support its injunctionagainst proceedings in state court. See 143 F.3d at 545-46."Where the district court expressly retains jurisdiction toenforce a settlement agreement, and to resolve disputes thatmay arise under it, litigation in state court would pose a sig-nificant risk of frustrating the district court's jurisdiction overthe consent judgment." Id. at 545 (internal quotation marksomitted) (citation omitted). Because the retention of jurisdic-tion to enforce water rights adjudications raises similar con-cerns, we conclude that the Anti-Injunction Act does not bara federal court injunction in this case.8 2. The Decision to Issue the Injunction[18] Federal courts are empowered by the All Writs Act, 28U.S.C. S 1651, to enjoin state court proceedings that interferewith federal judgments. See Keith v. Volpe, 118 F.3d 1386,1390 (9th Cir. 1997). As discussed above, the district courthad exclusive jurisdiction over appeals from decisions of theState Engineer regarding water rights adjudicated under theAlpine and Orr Ditch Decrees; its decision to issue the injunc-tion fits within the "necessary in aid of" exception to the Anti-Injunction Act. In light of the foregoing, there are no groundsto conclude that the district court abused its discretion inenjoining the state court proceeding. "Although comityrequires federal courts to exercise extreme caution in interfer-ing with state litigation, federal courts have the power to doso when their jurisdiction is threatened." Hanlon v. ChryslerCorp., 150 F.3d 1011, 1025 (9th Cir. 1998). Moreover,Nevada has expressly provided that where a court decree gov-erns water rights, a review of the State Engineer's decisions"shall be initiated in the court that entered the decree." Nev.Rev. Stat. S 533.450(1).C. DISTRICT COURT REVIEW OF STATE COURT INJUNCTIONFinally, Churchill County argues that the district court'sorder enjoining the Nevada state court proceeding amountedto direct federal district court review of a state court decision.Specifically, Churchill County objects to the district court'sruling that the state court's injunction is void for lack of juris-diction and that the state court misinterpreted a state statute.[19] Under 28 U.S.C. S 1257, the Supreme Court has juris-diction to review certain state court decisions. Under theRooker-Feldman doctrine, the lower federal courts do nothave this authority. See Feldman,
460 U.S. at 476
; Rooker,
263 U.S. at 416
. Churchill County is mistaken, however, incharacterizing the district court's actions as appellate reviewof a state court judgment. Although the district court opinedthat the state court had erred in interpreting a Nevada statute,the district court's decision amounted to a determination thatit had exclusive jurisdiction over the matter at issue and thatit needed to protect its exclusive jurisdiction. That is, the dis-trict court's decision rested on its own determination that ithad exclusive jurisdiction, not on any error on the part of thestate court in asserting jurisdiction.9 If Churchill County'sargument were to succeed, it would be impossible for a fed-eral court to enjoin a state court proceeding, despite satisfyingan exception to the Anti-Injunction Act, because the federalcourt would always be bound by the state court's determina-tion of jurisdiction. Moreover, as discussed above, this circuithas expressly upheld the admittedly "highly extraordinary"scheme of having the federal district court exercise appellatereview of the State Engineer's decisions in cases arising underthe Alpine and Orr Ditch Decrees. Alpine II, 878 F.2d at 1219n.2. Because this scheme does not require federal courtreview of Nevada state court proceedings, it also does notimplicate the Rooker-Feldman doctrine. Therefore, the districtcourt did not run afoul of the Rooker-Feldman doctrine.IV.The district court has continuing and exclusive jurisdictionto hear appeals from decisions of the Nevada State Engineerinvolving water rights adjudicated under the Alpine and OrrDitch Decrees. The injunction at issue in this case was neces-sary to protect the district court's exclusive jurisdiction.Therefore, the district court did not abuse its discretion byenjoining the Nevada state court proceeding. Accordingly, theorder of the district court isAFFIRMED.
___________________________FOOTNOTES 1 As a result of the State Engineer's decision to grant one of its applica-tions, the Fish and Wildlife Service withdrew its second application.2 Section 533.450 provides that "on stream systems where a decree ofcourt has been entered, the [appeal of the decision of the State Engineer]shall be initiated in the court that entered the decree." Nev. Rev. Stat.S 533.450 (1997).3 The injunction reads: THE COURT ORDERS that the Third Judicial District Court of Nevada's Order enjoining State Engineer R. Michael Turnipseed from proceeding in this action and enjoining this Court from pro- ceeding in this action is hereby held to be VOID as being entered without jurisdiction and in derogation of this Court's exclusive jurisdiction over the water rights at issue; . . . The Court ENJOINS further proceedings in Case No. 23656, Department No. II, in the Third Judicial District Court of the State of Nevada in and for the County of Churchill.(Emphasis in original).4 We express no view on this subject.5 We also reject Churchill County's argument that the district courtlacked jurisdiction because the State Engineer cannot satisfy the test forsupplemental jurisdiction under 28 U.S.C. S 1367. Supplemental jurisdic-tion under S 1367 is distinct from the equitable doctrine of ancillary juris-diction, which allows a court to adjudicate related claims "to manage itsproceedings, vindicate its authority, and effectuate its decrees." Kokkonenv. Guardian Life Ins. Co.,
511 U.S. 375, 380
(1994). The latter is at workhere. So long as the dispute in this case is related to the district court's ear-lier Decrees, the district court retains jurisdiction to adjudicate the dispute.6 The district court noted that Churchill County conceded that the federaldistrict court was the first court to acquire jurisdiction over the waterrights in question, a concession Churchill County disputes. The districtcourt's reliance on this supposed concession did not control the result itreached, however, because the district court found that it had gained juris-diction over the water rights at issue when the Orr Ditch and Alpine caseswere first filed in federal court. Therefore, whether there was ever such aconcession is irrelevant for purposes of this appeal.7 Churchill County contends that the decision of Landi v. Phelps, 740F.2d 710 (9th Cir. 1984), which held that a federal court may not enjoina state court proceeding merely because the federal court had exclusivejurisdiction over the matter, deprived the district court of authority toenjoin the state proceeding. See id. at 713. However, Landi involves nei-ther an in rem proceeding nor a situation where the federal court retainedjurisdiction. It is these factors that bring the instant case within the "whennecessary in aid of its jurisdiction" exception. [I]f the District Court does have jurisdiction, it is not enough that the requested injunction is related to that jurisdiction, but it must be "necessary in aid of" that jurisdiction. . . . [S]ome federal injunctive relief may be necessary to prevent a state court from so interfering with a federal court's consideration or disposition of a case as to seriously impair the federal court's flexibility and authority to decide that case.Atlantic Coast,
398 U.S. at 295
(emphasis in original).8 Because we agree with the district court that its injunction was properunder the "necessary in aid of its jurisdiction " exception, we offer no opin-ion on whether any other exceptions to the Anti-Injunction Act mightapply.9 In fact, the district court's disagreement with the Nevada state court'sinterpretation of state law was ultimately irrelevant to the district court'sdecision because the district court found that a state statute cannot strip afederal court of exclusive jurisdiction over an in rem action. the end