Sprint Communications Co. v. Jacobs


Should federal courts abstain from remedial actions—state administrative proceedings initiated by a private party—involving a federal question?

Sprint brought an action before the Iowa Utility Board to prevent Windstream, then called Iowa Telecom, from cutting off service to Sprint’s customers. After refusing Sprint’s request to cancel the hearing, the Board required Sprint to pay interstate access charges to Windstream. Sprint, thinking that the Iowa Utility Board did not have jurisdiction to make this determination, initiated suits in federal and state courts against Elizabeth S. Jacobs and other members of the Iowa Utility Board in their official capacity. In the federal suit, the district court granted the Board members’ abstention motion under Younger v. Harris—which requires a federal court to abstain from interfering with certain ongoing state judicial proceedings. The Eighth Circuit affirmed the abstention. The Supreme Court will clarify the difference between remedial and coercive actions, and determine whether Younger abstention applies to a federal suit when there is an ongoing remedial action in state court. The Court’s ruling implicates important issues of federalism including whether a party can seek federal judicial review of a state agency’s decision after the party voluntarily initiated the action.

Questions as Framed for the Court by the Parties: 

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."



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