Whether the Court of Appeals and the District Court erred in ignoring all precedents by holding that a federal court may not enjoin a state court order whose relief has a retaliatory or discriminatory effect which violates the Fair Housing Act

QUESTIONS PRESENTED Whether the Court of Appeals and the District Court erred in ignoring all precedents by holding that a federal court may not enjoin a state court order whose relief has a retaliatory or discriminatory effect which violates the Fair Housing Act, Specifically — Whether they ignored this Court’s precedents stated (1) in Mitchum v. Foster 407 U.S. 225 (1972) (that state court Claim Preclusion is inapplicable in federal FHA Retaliation cases) ; (2) in Bill Johnson's Restaurants, Inc. v. NLRB, 461 U.S. 731 (1983) (that use of state court process to obtain a retaliatory objective is itself retaliation, subsequently independently actionable in federal court); (3) in Nevada v. United States, 463 U.S. 110 (1983 (that prior to concluding “claim preclusion” a federal court must verify that the state and federal “causes of action” are i actually identical; (4) in Lawlor v. National Screen Service Corp., 349 U.S. 322 (1955) (which held that claim preclusion does not apply to any retaliatory transaction which occurred after the close of the prior state court proceedings; (5) in United States v. Throckmorton, 98 U.S. 61 (1878) (which held that extrinsic fraud by the defendant’s attorney in the state court deprives the state court’s final order of any claim preclusive effect; and (6) in Migra v. Warren City School Dist. Bd. of Ed., 465 US 75 which implicated South Carolina precedent stated in Plum Creek Dev. Co. v. City of Conway, 334 S.C. 30, 512 S.E.2d 106 (1999) (which holds that permissive claims not litigated in state court have no claim preclusive effect in a later federal court proceeding. ii