Sprint Communications Inc. v. Jacobs
December 10, 2013
Case #: 12-815
Ginsburg, J., delivered the Court’s unanimous opinion.
Full Text Opinion: http://www.supremecourt.gov/opinions/13pdf/12-815_qol1.pdf
Civil Procedure: Abstention in civil cases invoking Younger v. Harris, 401 U.S. 37 in federal courts extends only to the three “exceptional circumstances” determined in New Orleans Public Services Inc. v. Council of City of New Orleans, 491 U.S. 350.
Respondent determined that intercarrier access fees imposed by local telecommunications companies were not preempted by the federal Telecommunications Act of 1996. Petitioner filed suit in federal court arguing that the issue was governed by federal law as well as filing a suit in state court to review Respondent’s order. The Federal District Court abstained from adjudicating Petitioner’s claim, citing Younger v. Harris, 401 U.S. 37, because of a parallel proceeding in state court. The Eight Circuit Court of Appeals concurred with the Federal Court’s determination and affirmed the decision based on the state court proceeding involving the state’s important interest in state utility rate regulation.
The Supreme Court reversed and held that the present case did not meet any of the criteria in Younger in which abstention would be appropriate. New Orleans Public Services Inc. v. Council of City of New Orleans, 491 U.S. 350 (NOPSI), found that there were three “exceptional circumstances” in which abstention is appropriate under Younger: (1) prevents federal courts from hearing criminal cases when there is a current state criminal proceeding, (2) “civil enforcement proceedings” that is "akin to criminal prosecution" in state court, and (3) that federal courts should not interfere in civil proceedings involving orders that are in "the furtherance of the state courts’ ability to perform their judicial functions."
The Eight Circuit Court of Appeals cited Middlesex County Ethics Comm. v. Garden State Bar Assn., 457 U.S. 423 when affirming the district court’s decision. Middlesex, provides that abstention under Younger is allowed when (1) there is “an going state judicial proceeding, which (2) implicates important state interests, and (3) . . . provide[s] an adequate opportunity to raise [federal] challenges.” The Supreme Court determined that the conditions in Middlesex were additional factors that a federal court might use, but the conditions are not dispositive and that abstention under Younger extends to the three “exceptional circumstances” in NOPSI but not any farther.