Bennett

This case requires us to address the scope of the Anti-Injunction Act, 28 U.S.C. § 2283 , in the context of a district court order restraining the parties from seeking to enforce non-compete agreements in state court. The Anti-Injunction Act prohibits a federal court from enjoining state court proceedings except “as expressly authorized by ... Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments.” Id. Because none of the exceptions are applicable here, we reverse the grant of injunctive relief.

Background

1. The parties

This suit arises from Medtronic, Inc.’s effort to enforce covenants not to compete against former employees. Such covenants are variously referred to as non-compete or non-competition agreements. Medtronic acquired Sofamor Danek, Inc. and created a subsidiary, Medtronic Sofa-mor Danek, which is based in Memphis, Tennessee (collectively “Medtronic”). One of Medtronic’s direct competitors is San Diego-based NuVasive, Inc. Both Med-tronic and NuVasive design and manufacture devices relating to spinal surgery.

Three former Medtronic employees, Rufus Bennett, Keith Valentine, and Patrick Miles (collectively “the…