Hicks v. Miranda, 422 U.S. 332 (1975), was a United States Supreme Court case in which the Court held that the Anti-Injunction Act does apply to state criminal proceedings initiated after a federal complaint is filed but before there has been a "proceeding of substance on the merits" in federal court.. The case involved the pornographic film Deep Throat.
Significance Among other things, this case emphasized that summary opinions from the Supreme Court can still have precedential value, even if that value is less than a full opinion. A summary opinion is one where the court simply announces its decision in a per curiam opinion, often with little reasoning. Hicks advises that such an opinion is binding "until such times as the Court informs [the lower courts] that [it is] not."
See also Younger v. Harris
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