Bennett v. Medtronic, Inc., 285 F.3d 801 (9th Cir. 2002)

Medtronic, Inc. sued three of its former California employees and their new employer, NuVasive, in Tennessee following the employees’ resignation from Medtronic and acceptance of employment with NuVasive, one of Medtronic’s competitors in the business of designing and manufacturing spinal surgery devices. Among other things, Medtronic sought to enforce a non-competition agreement the employees had signed during their employment with Medtronic. On the same day that Medtronic filed suit in Tennessee, the employees filed suit in California, seeking to invalidate the non-compete agreements under California Business and Professions Code § 16600 and to enjoin Medtronic from taking further steps in the Tennessee court that would impair the employees’ rights as California citizens and employees. After the matter was removed to federal court in San Diego, the district court granted the employees’ application for a temporary restraining order, thus precluding Medtronic from further litigating the matter in Tennessee. The Ninth Circuit reversed the district court’s order pursuant to the provisions of the federal Anti-Injunction Act, which prohibits a federal court from granting an injunction to stay proceedings in a state court action absent certain circumstances not applicable in this case.