Micron Technology, Inc. v. Netlist, Inc., 1:24-cv-00001

Micron sued Netlist in Idaho state court, alleging Netlist violated the Idaho Bad Faith Assertions of Patent Infringement Act by asserting a patent in bad faith.
Netlist removed the case to federal court, asserting federal jurisdiction.
The federal court found there was no subject matter jurisdiction (the case did not arise under federal patent law) and ordered remand to state court.
Netlist appealed the remand order to the Federal Circuit and also sought a stay of the remand order (meaning to pause the effect of the order sending the case back to state court) in both the district court and Federal Circuit.
The district court considered Netlist’s motion to stay the remand order pending appeal.

Issue	Micron's Argument	Netlist's Argument	Held
Whether district court has jurisdiction to stay its own remand order after remand is certified	District court lacks jurisdiction once remand is certified to state court.	Court retains limited jurisdiction to grant stay when remand order is appealable, else right to appeal is hollow.	District court lacks jurisdiction to act after remand is certified; only appeals court can grant a stay.

Seedman v. U.S. Dist. Court for Cent. of Dist. California, 837 F.2d 413 (9th Cir. 1988) (a district court is divested of jurisdiction once it certifies a remand order to state court)
Griggs v. Provident Consumer Discount Co., 459 U.S. 56 (1982) (filing notice of appeal confers jurisdiction on court of appeals and divests the district court of jurisdiction)
Hart v. Massanari, 266 F.3d 1155 (9th Cir. 2001) (district courts must follow circuit precedent even if another approach seems reasonable)