'Younger' But Wiser? SCOTUS to Hear Sprint v. Jacobs

By Aditi Mukherji, JD on October 08, 2013 | Last updated on March 21, 2019

The U.S. Supreme Court granted certiorari to a fee dispute case that sprung from the Eighth Circuit between a Sprint Nextel Corp. subsidiary and the utilities regulator in Iowa, reports Reuters.

But it's not actually about fees.

Central to the dispute is whether the Eighth Circuit Court of Appeals erred in applying the abstention doctrine set forth by Younger v. Harris. The Eighth Circuit concluded that the Younger abstention is warranted when there is a related state proceeding that is "remedial" as opposed to "coercive," rejecting a distinction between the two.

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Fee Dispute, Preemption and Abstention -- Oh My!

The Iowa Utilities Board (IUB) ordered Sprint to pay intrastate access charges to Windstream, an Iowa communications company, for Voice over Internet Protocol (VoIP) calls. Sprint refused to pay up and filed a complaint in federal district court seeking declaratory and injunctive relief.

The same day, Sprint also filed a petition for review in Iowa state court, asserting that the IUB's order was preempted under federal law.

The federal district court abstained from hearing the case pursuant to Younger v. Harris, in which the U.S. Supreme Court held that federal courts are required to abstain from hearing any civil rights tort claims brought by a person who is currently being prosecuted for a matter arising from that claim in a state proceeding ("Younger abstention").

Precedent holds that Younger abstention applies when:

  1. there is an ongoing state judicial proceeding, which
  2. implicates important state interests, and
  3. the state proceedings provide an adequate opportunity to raise constitutional challenges.

Sprint argued that Younger only applies to coercive proceedings, whereas the proceedings in this case are remedial. Nonetheless, the district court abstained and dismissed the action.

The Eighth Circuit rejected the distinction between "coercive" and "remedial" being outcome determinative and affirmed the lower court's decision.

The Issue for SCOTUS

The question before the Court is whether the Eighth Circuit erred by concluding, in conflict with decisions of nine other circuits and this Court, that Younger abstention is warranted not only when there is a related state proceeding that is "coercive" but also when there is a related state proceeding that is, instead, "remedial."

Is there a distinction between the two? We'll just have to wait and see how SCOTUS weighs in on the issue.

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