Supreme Court Docket Report - April 15 2013

Keywords: Younger, abstention, court interference, ERISA, limitations period, adverse benefits determinations

On April 15, 2013, the Supreme Court granted certiorari in two cases of interest to the business community:

Federal Courts - Younger Abstention

Under the judicially created doctrine of abstention, federal courts are required to abstain from deciding certain cases over which they otherwise have jurisdiction, in order to prevent "interference" with related state-court proceedings. In Younger v. Harris, 401 U.S. 37, 43 (1971), the Supreme Court held that, based on a "longstanding public policy against federal court interference with state court proceedings," federal courts should not enjoin a state criminal prosecution begun before institution of the federal suit. Younger has since been extended beyond state criminal proceedings; and in Middlesex County Ethics Committee v. Garden State Bar Association, 457 U.S. 423 (1982), the Court held that Younger abstention is appropriate when (1) there is an ongoing state judicial proceeding that (2) implicates important state interests, and (3) the state proceedings provide an adequate opportunity to raise constitutional challenges. Today, the Supreme Court granted certiorari in Sprint Communications Co. v. Jacobs, No. 12-815, to clarify which types of state proceedings require Younger abstention.

Sprint had a dispute with Windstream, an Iowa communications company, over access charges for "voice over Internet protocol" calls. Sprint sought declaratory relief from the Iowa Utilities Board, which found that Sprint was required to pay the access charges. Sprint then filed a complaint in federal district court, arguing that only the Federal Communications Commission has authority to decide the issue. At the same time, Sprint petitioned for review of the IUB's decision in Iowa state court. The district court dismissed the federal case on abstention grounds.

The Eighth Circuit affirmed, holding that Younger abstention was appropriate because the three Middlesex factors were met. Sprint had argued that Younger abstention could not apply because the state's enforcement interests were not implicated by the proceeding, which was "remedial" rather than "coercive." In rejecting this argument, the court of appeals explained that, "[a]lthough we have recognized the existence of the coercive-remedial distinction in other of our abstention cases, we have not considered the distinction to be outcome...