Supreme Court Decision Alert - December 10, 2013

Today (December 10, 2013) the Supreme Court issued two decisions, described below, of interest to the business community.

Federal Courts—Younger Abstention Labor-Management Relations Act—Effect of Anti-Bribery Statute on Voluntary-Recognition Agreements Federal Courts—Younger Abstention

Sprint Communications Co. v. Jacobs, No. 12-815 (previously discussed in the April 15, 2013, Docket Report)

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 (1971), the Supreme Court held that when there is a parallel, pending state criminal proceeding, federal courts must refrain from enjoining the state prosecution. Younger has since been extended to certain state civil proceedings. Today, in Sprint Communications Co. v. Jacobs, the Supreme Court clarified Younger's scope and reiterated that Younger abstention applies only in exceptional circumstances.

The case is significant for the business community because it will affect which cases will be heard by federal, rather than, state courts.

The petitioner, 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. In seeking to overturn the Board's decision, Sprint commenced two lawsuits. The first was a complaint filed in federal district court, arguing that the Board's decision was preempted by the Telecommunications Act of 1996. In the second suit, Sprint petitioned for review of the Board's order in Iowa state court. Sprint claimed that it filed the state suit as a protective measure in the event that the federal court required it to first exhaust state remedies.

In light of the state suit, the district court dismissed the federal case on abstention grounds. The Eighth Circuit affirmed based on its reading of Middlesex County Ethics Committee v. Garden State Bar Association, 457 U.S. 423 (1982), holding that Younger abstention is warranted whenever "an ongoing state judicial proceeding . . . implicates important state interests, and . . . the state proceedings provide adequate opportunity to raise [federal] challenges." 690 F.3d 864, 867.

In a unanimous opinion by Justice Ginsburg, the...