Bhargav Patel, et al. v. Government Employees Insurance Company, et al.

Since 1793, the Anti-Injunction Act (“AIA”) has prohibited federal courts from staying pending statecourt proceedings except in three narrow circumstances, one of which is where an injunction is “expressly authorized” by Act of Congress. 28 U.S.C. § 2283. In the more than two centuries since, this Court has recognized only a handful of statutes as expressly authorizing such an injunction—each of which either halts state proceedings on its face or addresses state proceedings that themselves violate federal law. In the decision below, the Second Circuit held that the Racketeer Influenced and Corrupt Organizations Act (“RICO”) “expressly authorizes” a federal court to enjoin more than 600 pending statecourt collection actions and arbitrations that all parties concede are not themselves RICO violations, on the ground that those proceedings “help further” an alleged RICO scheme. The question presented is: Whether the Anti-Injunction Act’s “expressly authorized” exception, 28 U.S.C. § 2283, permits a federal court to enjoin pending state-court proceedings that do not themselves violate any federal statute and as to which the federal claimant retains a complete defense and a federal damages remedy, where the federal plaintiff alleges only that the state proceedings “help further” a RICO violation.