Supreme Court Decides Sprint Communications, Inc. v. Jacobs
On December 10, 2013, the Supreme Court of the United States decided Sprint Communications, Inc. v. Jacobs, No. 12-815, holding that a federal court may abstain from adjudicating a complaint in deference to parallel state-court proceedings only for three exceptional categories of cases: (1) ongoing criminal prosecutions, (2) civil enforcement proceedings akin to criminal prosecutions, and (3) civil proceedings "uniquely in furtherance of the state courts' ability to perform their judicial functions."
Sprint, a national telecommunications carrier, paid "intercarrier access fees" to an Iowa telecommunications company, Windstream, for long-distance calls placed by Sprint customers to Windstream's in-state customers. In 2009, Sprint withheld payment for a subset of those calls (for Voice over Internet Protocol, or VoIP, calls) after concluding that such intrastate regulation was preempted by the Telecommunications Act of 1996. To resolve the issue, Sprint filed a complaint with the Iowa Utilities Board (IUB), but the IUB ruled that intrastate fees applied to VoIP calls. Sprint then challenged that ruling in both state court and federal court lawsuits, again arguing that the Telecommunications Act preempted state regulation of VoIP calls.
In the federal proceeding, the IUB moved the district court, under the Supreme Court's decision in Younger v. Harris, 401 U.S. 37 (1971), to abstain in light of the parallel state-court proceeding also filed by Sprint. The district court granted the motion, and the Court of Appeals for the Eighth Circuit affirmed. The Eighth Circuit reasoned that abstention under Younger was appropriate whenever "an ongoing state judicial proceeding implicates important state interests" and the state proceedings provided an adequate opportunity to raise federal challenges.
The Supreme Court reversed, holding that a federal court may abstain from adjudicating a complaint in deference to parallel state-court proceedings only for three exceptional categories of cases: (1) ongoing criminal prosecutions, (2) civil enforcement proceedings akin to criminal prosecutions, and (3) civil proceedings "uniquely in furtherance of the state courts' ability to perform their judicial functions." The Court reasoned that federal courts have a "virtually unflagging" obligation to hear and decide a case, including cases where a parallel state-court proceeding is pending. The only exceptions to this general rule, the Court explained, were for ongoing state criminal proceedings, ongoing civil enforcement actions closely resembling criminal proceedings, and civil proceedings "uniquely in furtherance of the state courts' ability to perform their judicial functions."
The Court concluded that the IUB's proceeding did not fall into any of those three narrow exceptions to the general rule. The only category possibly applicable—for proceedings "akin" to a criminal prosecution—was reserved generally for state actions initiated by state actors involving investigations and culminating in the filing of a formal complaint or charges. The IUB proceeding was not such a case, as it was filed by one private party against another. The Court thus rejected the Eighth Circuit's broader interpretation of Younger abstention; to extend Younger to any case that implicates an ongoing state judicial proceeding and important state interests, the Court concluded, would "extend Younger to virtually all parallel state and federal proceedings."
Justice Ginsburg delivered the opinion for a unanimous court.
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