With no explanation, chose the best option from "A", "B", "C" or "D". of contempt and sentenced relator to 180 days in jail. Relator was incarcerated September 13, 1996. After the court of appeals denied ha-beas corpus relief, Evans sought relief from this Court. We ordered him released on bond pending our consideration of the merits. Subject to certain exceptions, state courts have authority to enjoin litigation in other state courts, either of their own or other states. See, e.g., Golden Rule Ins. Co. v. Harper, 925 S.W.2d 649 (Tex.1996). However, it is settled that “state courts are completely without power to restrain federal court proceedings in in personam actions.” Donovan v. City of Dallas, 377 U.S. 408, 413, 84 S.Ct. 1579, 1582, 12 L.Ed.2d 409 (1964). See also General Atomic Co. v. Fetter, 434 U.S. 12, 16, 98 S.Ct. 76, 78, 54 L.Ed.2d 199 (1977) (<HOLDING>); Gannon v. Payne, 706 S.W.2d 304, 305

A: holding that the donovan rule applies regardless of whether the injunction is issued before or after the federal court filing
B: holding that the plra bar applies to lawsuits brought by inmates regardless of whether the inmate is incarcerated at the time of filing or whether the plaintiff is subsequently paroled sentenced or released
C: holding that when the supreme court applies a rule of federal law to the parties before it that rule is the controlling interpretation of federal law and must be given full retroactive effect in all cases still open on direct review and as to all events regardless of whether such events predate or postdate our announcement of the rule
D: holding that when the district court applies the wrong preliminary injunction standard this court may review the record to determine whether the injunction is justified
A.