## Facts

- Standard Microsystems Corporation (SMC) and Texas Instruments Incorporated (TI) entered a 1976 patent cross-licensing agreement granting reciprocal royalty-free use of certain semiconductor technology, with confidentiality and non-assignment provisions.
- SMC sought to transfer or offer its royalty-free rights to use TI technology to Japanese and Korean entities; TI asserted this would breach the agreement.
- On January 19, 1990, SMC sued TI in the Eastern District of New York, alleging antitrust and securities violations and breach of contract, and sought declaratory relief that its proposed transaction would not breach the agreement.
- The district court issued a temporary restraining order preventing TI from terminating or revoking SMC’s rights under the agreement.
- On January 22, 1990, TI filed a related action against SMC in Texas state court.
- On January 26, 1990, the district court enjoined TI from prosecuting the Texas state-court action.
- TI appealed, arguing the injunction violated the Anti-Injunction Act, 28 U.S.C. § 2283.

## Issues

1. Whether the Anti-Injunction Act barred the federal district court from enjoining TI’s later-filed Texas state-court action.
2. Whether any exception to 28 U.S.C. § 2283 applied: (a) expressly authorized by Act of Congress, (b) necessary in aid of jurisdiction, or (c) to protect or effectuate judgments.

## Decision

- The court of appeals vacated the injunction prohibiting TI from prosecuting the Texas state-court action.
- The Anti-Injunction Act imposed a strict bar on enjoining state proceedings, and none of the statute’s three exceptions applied.
- The case was remanded for further proceedings in federal court without any restriction on the parallel Texas litigation.

## Legal Principles

- 28 U.S.C. § 2283 generally forbids federal courts from enjoining state-court proceedings unless one of three narrow statutory exceptions applies.
- The “expressly authorized” exception requires a federal statute that clearly contemplates injunctions against state proceedings; general federal causes of action or jurisdictional statutes are insufficient.
- The “necessary in aid of its jurisdiction” exception is typically limited to circumstances such as in rem (or similar) proceedings, exclusive federal jurisdiction, or situations requiring protection of a res or comparable federal control; ordinary in personam disputes do not qualify.
- The “protect or effectuate its judgments” (relitigation) exception requires a prior federal judgment that would otherwise be undermined by state-court relitigation; interim orders such as a TRO do not satisfy this requirement.
- The existence of parallel state and federal actions, even if duplicative and involving overlapping issues, does not itself justify a federal injunction against the state proceeding.

## Conclusion

The court held that the district court lacked authority under the Anti-Injunction Act to halt TI’s Texas state suit, because no statutory exception permitted the injunction; the injunction was therefore vacated and the parties were left to proceed in both forums.


Standard Microsystems Corp. v. Texas Instruments Inc., 916 F.2d 58 (2d Cir. 1990)