SFM Holdings Ltd, et al. v. Banc of America Securities, LLC, No. 13-10563 (11th Cir. 2014)
Annotate this CaseThe district court enjoined SFM from prosecuting an action in Florida state court against BAS. On appeal, SFM challenged the issuance of the injunction, arguing that it does not fall within the narrow "relitigation exception" to the Anti-Injunction Act, 28 U.S.C. 2283. The court held that SFM's state court action presents some legal claims that differ from those decided in the prior federal action. With respect to other claims now advanced by SFM, however, the court concluded that the district court had the authority to enjoin their relitigation in state court. Accordingly, the court affirmed in part, reversed in part, and remanded.
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