Advanced Bionics Corp. v. Medtronic (2002) 29 Cal.4th 697

Horvitz & Levy LLP represented Medtronic, the successful petitioner in this California Supreme Court Case, in which the court delineated for the first time in over a century the circumstances under which California trial courts may enjoin parallel court proceedings in other states. (Read the publicly-filed redacted version of the opening brief on the merits.)

Mark Stultz worked in Minnesota for Medtronic, one of the world's largest healthcare device manufacturers. Because Stultz had access to Medtronic trade secrets concerning the development of spinal cord stimulation devices (used to alleviate back pain), Medtronic insisted as a condition of employment that Stultz agree not to work on spinal cord stimulators if Stultz left to work for any of Medtronic's competitors.

Stultz left Medtronic in June 2000 to work in California on the development of spinal cord stimulation devices for Advanced Bionics Corp. of Sylmar, California. The same day that Stultz announced his resignation from Medtronic, Advanced Bionics and Stultz filed suit in California seeking to invalidate the employment restriction in Stultz's contract with Medtronic.

After Medtronic filed its own suit in Minnesota seeking to uphold the restriction in Stultz's contract, the California trial court issued an order that prohibited Medtronic from pursuing the Minnesota action and effectively stopped the Minnesota court proceedings from going forward. Medtronic appealed this order, which the California Court of Appeal upheld.

The California Supreme Court overturned the Court of Appeal's decision and the lower court's injunction against the Minnesota proceedings. Citing the need for states not to interfere with one another's judicial proceedings, the court limited the circumstances in which a California trial court can issue orders restraining judicial proceedings in another state. Finding that Advanced Bionics' case against Medtronic did not qualify for this extraordinary type of relief, the court vacated the trial court order in favor of allowing each state to decide the course of its own judicial proceedings.

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