State Farm Mutual Automobile Insurance Co. v. Tri-Borough NY Medical Practice P.C.
The Second Circuit reversed the district court's denial of a preliminary injunction against pending state-court proceedings, holding that an exception to the Anti-Injunction Act applies where federal arbitration claims are at stake and state litigation threatens irreparable harm. Applying the standard for enjoining state court actions under 28 U.S.C. § 2283, the court found State Farm likely to succeed on its claim that the Federal Arbitration Act preempts the state proceedings.