of
property, such jurisdiction cannot be taken away or obstructed by
proceedings in another court, nor can the possession of the property be
disturbed by proceedings in another court; and the court which has first
acquired jurisdiction of the cause or the possession of the _res_ has
exclusive jurisdiction to hear and determine the case and all
controversies relating thereto, provided that the subject matter of the
suit, the remedies sought, and the parties to it are the same, and
provided further that it is not necessary for the federal courts to
exercise jurisdiction in order to enforce the supremacy of the
Constitution and laws of the United States.[655]

STATE INTERFERENCE BY INJUNCTION WITH FEDERAL JURISDICTION

It has long been settled as a general rule that State courts have no
power to enjoin proceedings or judgments of the federal courts.[656] In
United States ex rel. Riggs _v._ Johnson County[657] this rule was
attributed to no paramount jurisdiction of the federal courts, but
rather to the complete independence of the State and federal courts in
their spheres of action. Like many of the rules governing federal-state
court relations, this rule is not absolute, as shown by a case arising
in Pennsylvania. Two surviving trustees had filed an account for
themselves and a deceased trustee in a court of common pleas.
Thereafter, two of the five beneficiaries sued the two trustees and the
deceased trustee in a federal district court, charging mismanagement and
praying for an accounting and restitution and removal of the trustees.
The Supreme Court held that the State court upon the filing of the
account acquired jurisdiction over the trust _quasi in rem_ exclusively
and therefore sustained the State court's injunction restraining the
parties from further proceeding in the federal court while
simultaneously holding that the district court could not enjoin the
parties from proceeding in the State court.[658] The power of a State
court to enjoin parties from proceeding in a federal court obviously
does not include that of enjoining a federal court.

FEDERAL INTERFERENCE BY INJUNCTION WITH STATE JURISDICTION

The discretion of the federal courts to enjoin proceedings in State
courts has not been left exclusively to doctrines of comity, for since
1793 the federal courts have been prohibited by statute from restraining
proceedings in State courts.[659] Initially this statute was applied
with strict literalness in co