February 14, 2014 Top Story

Supreme Court Narrowly Defines Younger Abstention Doctrine

Abstention by federal courts appropriate only in exceptional circumstances

Sara E. Costello

Federal courts should abstain from deciding cases only in “exceptional” circumstances, the U.S. Supreme Court reinforced in Sprint Communications, Inc. v. Jacobs. In a strongly worded decision, the Supreme Court explained that federal courts have a “virtually unflagging” obligation to hear cases within their jurisdiction. The unanimous ruling emphasizes that abstention pursuant to Younger v. Harris is not appropriate merely because a state court is considering a case involving the same subject matter.

Federal Court Abstains From Hearing Telecommunications Dispute

Sprint Communications, Inc. filed suit against the Iowa Utilities Board (IUB) over a dispute about intrastate fees imposed on Internet telephone calls. Sprint filed a complaint in the U.S. District Court for the Southern District of Iowa alleging that the Telecommunications Act of 1996 preempted the IUB’s adverse ruling on fees. In addition, Sprint filed suit in Iowa state court, raising the same preemption argument along with due process claims.

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