RESPONDENT: Elizabeth S. Jacobs, et al.
LOCATION: United States District Court for the Southern District of Iowa
DOCKET NO.: 12-815
DECIDED BY: Roberts Court (2010-2016)
CITATION: 571 US (2013)
GRANTED: Apr 15, 2013
ARGUED: Nov 05, 2013
DECIDED: Dec 10, 2013
David J. Lynch - for the respondents
Timothy J. Simeone - for the petitioner
Facts of the case
In January 2010, Sprint Communications Co. filed a complaint with the Iowa Utilities Board ("IUB") asking for a declaration that it was proper to withhold certain VoIP call access charges from Windstream (formerly Iowa Telecom). Before IUB addressed the complaint, Sprint settled the dispute with Windstream and withdrew its complaint. However, IUB continued the proceeding so that it could decide a greater underlying issue of how VoIP communications should be classified under federal law. In February 2011, IUB issued an order with its own interpretation of VoIP's classification under federal law along with a determination that Sprint was liable to Windstream for the access charges.
Sprint challenged IUB's order by filing a complaint in both state court and federal district court, alleging that federal law preempts the IUB's decision. In order to proceed with the federal complaint first, Sprint filed a motion to stay the state case until resolution of the federal case. In turn, the IUB filed a motion asking the federal court to abstain and dismiss the case under the doctrine of Younger v. Harris. Generally, this doctrine states that a federal court shall abstain from hearing a case if there is a threat of interference with a state court proceeding involving important state interests. The district court granted IUB's motion and dismissed Sprint's federal complaint. Sprint appealed to the United States Court of Appeals for the Eighth Circuit, which upheld the district court's abstention, but determined that a stay on the federal proceedings was more appropriate than dismissal.
Should a federal court abstain under the Younger doctrine when there is no related coercive or enforcement action by the State interfering with the federal proceeding?
Media for Sprint Communications Co. v. JacobsAudio Transcription for Oral Argument - November 05, 2013 in Sprint Communications Co. v. Jacobs
Audio Transcription for Opinion Announcement - December 10, 2013 in Sprint Communications Co. v. Jacobs
Justice Ginsburg has our opinion this morning in case 12-815, Sprint Communications versus Jacobs.
This case concerns the -- a federal court's authority to refrain from exercising jurisdiction over a case in deference to a parallel state court proceeding.
Propeller of the controversy, Sprint Communications is a national telecommunications service provider.
Sprint withheld payment of intercarrier access fees imposed by Windstream Iowa Communications, an Iowa telecommunications carrier.
The fees withheld were for certain long distance calls transported over the internet.
Such calls Sprint said, was subject to federal, not state regulation.
When Windstream threatened to block calls to and from Sprint customers unless Sprint paid the access fees, Sprint asked the Iowa Utilities Board to rule on the matter.
The Board did so ruling in favor of Windstream.
Federal law, the Board concluded, did not preempt the application of intrastate fees to the type of calls in dispute.
Seeking to overturn the Board's rulings, Sprint commenced two lawsuits.
First, Sprint sued the members of the Iowa Board in the United States District Court for the Southern District of Iowa.
And second, Sprint petitioned for review of the Board's order in Iowa state court.
The Board asked Federal District Court to abstain in deference to the state suit citing this Court's 1971 decision in Younger v. Harris which barred federal court interference with state criminal prosecutions.
The District Court held that abstention was the proper course in Sprint's case.
On appeals, the Eighth Circuit agreed.
We rather review to decide whether abstention was appropriate.
We hold that it was not, and reversed the Eighth Circuit's judgment.
In the main, federal courts are obliged to decide cases over which they have jurisdiction.
Abstention is not an order simply because a pending state court proceeding involves the same subject matter as the federal proceeding.
This Court has identified however certain instances in which the prospect of undue interference with state proceeding counsels against federal relief.
Younger exemplifies one class of cases in which federal court abstention is required.
When a parallel state criminal proceeding is on the way, federal courts must let the state prosecution run its course.
The court has extended the Younger doctrine to certain civil proceedings, but circumstances fitting within the doctrine remained exceptional.
In New Orleans Public Service v. Council of City of New Orleans or NOPSI, the court surveyed and catalogued prior decisions resting on Younger.
Our opinion in NOPSI described three exceptional categories of cases warranting Younger style abstention, state criminal prosecutions, civil enforcement proceedings, and civil proceedings implicating a state's interest in enforcing the orders and judgments of its courts.
These three categories we hold today delineate Younger's domain.
The Iowa Board proceeding we conclude does not fall within any of these three categories and therefore does not trigger the Younger abstention.
The Board proceeding with civil, not criminal in character and did not touch on the state court's ability to perform its judicial function, nor is the Board's adjudication promptly tied a civil enforcement proceeding, a private corporation, Sprint initiated the action.
No state authority conducted an investigation into Sprint's activities, no state actor, launched the complaint agents.
Sprint in short, nothing about the Board proceeding appears akin to a criminal proceeding.