Sprint Communications Co. v Jacobs
April 15, 2013
Case #: 12-815
Court Below: 690 F.3d 864 (8th Cir. 2012)
Full Text Opinion: http://media.ca8.uscourts.gov/opndir/12/09/112984P.pdf
Civil Procedure: Whether the United States Court of Appeals, Eighth Circuit erred in applying the abstention doctrine to a review a "coercive" or "remedial" state proceeding.
Petitioner filed a grievance in federal court contesting an order to pay intrastate access charges for Voice over Internet Protocol calls. Additionally, Petitioner filed in state court. The Younger abstention doctrine ensures that states may try cases free from federal judicial interference. Younger protects states' enforcement interests.
Petitioner filed suit in federal district court. The district court dismissed the suit on abstention grounds citing Younger v Harris. Petitioner appealed to circuit court which found the dismissal on abstention grounds valid. The court found that the two prongs of Younger that were argued, (1) there is an ongoing state judicial proceeding, which (2) implicates an important state interest were met. The Eighth circuit found that interest in federalism and comity prohibit federal interference when there is a lack of state judicial review and that the state has a substantial and legitimate interest in regulating intrastate retail rates. The court rejected the "coercive" and "remedial" distinction, affirmed in part, vacated in part and remanded to state court. Petitioner appeals to the Supreme Court.
The Supreme Court granted certiorari to resolve whether the United States Court of Appeals, Eighth Circuit erred in applying the abstention doctrine to a review a "coercive" or "remedial" state proceeding.