## Facts

- Vendo Company acquired most assets of a vending-machine manufacturer controlled by Harry H. Stoner and related entities.
- As part of the transaction, Stoner and affiliated companies agreed to noncompetition covenants restricting participation in the manufacture or sale of vending machines.
- After the business relationship deteriorated, Vendo sued Stoner and related entities in Illinois state court for breach of the noncompetition covenants.
- Shortly after the state suit began, Stoner-related parties filed a federal action alleging the noncompetition covenant was an unreasonable restraint of trade violating Sherman Act §§ 1 and 2.
- The federal antitrust case remained largely inactive while the state litigation proceeded.
- Illinois courts entered, and the Illinois Supreme Court affirmed, a judgment exceeding $7 million in Vendo’s favor for breach of the noncompete.
- After the state judgment became enforceable, the federal antitrust plaintiffs sought a preliminary injunction under Clayton Act § 16 to stop Vendo from collecting the state-court judgment.

## Issues

1. Whether Clayton Act § 16 “expressly authorizes” a federal court to enjoin enforcement of a state-court judgment notwithstanding the Anti-Injunction Act, 28 U.S.C. § 2283.
2. Whether enjoining collection of the state-court judgment was “necessary in aid of” the federal court’s jurisdiction under § 2283.

## Decision

- The Supreme Court reversed the judgment upholding the injunction and remanded.
- A plurality concluded that § 16 of the Clayton Act was not an “expressly authorized” exception to § 2283 on these facts.
- The plurality also concluded the injunction was not “necessary in aid of” federal jurisdiction.
- A separate concurrence agreed the injunction could not stand in this posture, without fully adopting the plurality’s broader statutory reasoning.
- The dissent would have affirmed, reading § 16 as permitting injunctive relief that can reach state proceedings when needed for effective antitrust enforcement.

## Legal Principles

- The Anti-Injunction Act bars federal courts from enjoining state-court proceedings, including enforcement of state judgments, unless one of § 2283’s exceptions is satisfied.
- The “expressly authorized” exception requires more than general statutory language permitting injunctions; the statute must show congressional intent to permit federal injunctions that interfere with state proceedings when needed to protect the federal right or remedy.
- Clayton Act § 16 does not, in the circumstances presented, supply the specific authorization required to enjoin enforcement of a final state-court judgment.
- The “necessary in aid of its jurisdiction” exception is narrowly applied and generally concerns protection of federal control over a res or comparable circumstances; the possibility that enforcement of a state judgment will financially impair a federal plaintiff is insufficient.
- Federal courts may not use private antitrust injunctive remedies as a vehicle to neutralize the effects of an adverse, final state-court judgment absent a valid § 2283 exception.

## Conclusion

The Court held that the Anti-Injunction Act barred a federal injunction preventing collection of a final Illinois judgment, rejecting reliance on Clayton Act § 16 and concluding that potential financial harm to the federal antitrust plaintiffs did not make an injunction “necessary in aid of” federal jurisdiction.


Vendo Co. v. Lektro-Vend Corp., 433 U.S. 623 (1977)