478
Opinion of the Court
the plaintiffs "had attempted to avoid removal jurisdiction by artfully casting their essentially federal[-]law claims as state-law claims." Ibid. (internal quotation marks omitted).
"Moitie's enigmatic footnote," Rivet, 108 F. 3d, at 584, we recognize, has caused considerable confusion in the circuit courts. We therefore clarify today that Moitie did not create a preclusion exception to the rule, fundamental under currently governing legislation, that a defendant cannot remove on the basis of a federal defense.
In sum, claim preclusion by reason of a prior federal judgment is a defensive plea that provides no basis for removal under § 1441(b). Such a defense is properly made in the state proceedings, and the state courts' disposition of it is subject to this Court's ultimate review.3
* * *
For the foregoing reasons, the judgment of the Court of Appeals for the Fifth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
3 We note also that under the relitigation exception to the Anti-Injunction Act, 28 U. S. C. § 2283, a federal court may enjoin state-court proceedings "where necessary . . . to protect or effectuate its judgments." Ibid.
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