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abstention

Republic of Hungary v. Simon

Issues

Do district courts have the discretion to abstain from exercising jurisdiction under the Foreign Sovereign Immunities Act for reasons pertaining to international comity?

 This case asks the Supreme Court to decide whether the common-law doctrine of international comity provides federal courts with the discretion to dismiss claims under the Foreign Sovereign Immunities Act (“FSIA”). Respondent the Republic of Hungary argues that the FSIA must be construed in light of international comity doctrine, and that the federal court should defer to Hungary as Hungary’s interests in hearing this case outweigh those of the United States. Petitioners Rosalie Simon and other Hungarian Holocaust survivors argue that the FSIA has displaced common law and that federal courts should exercise jurisdiction in cases such as this one, where a sovereign state has failed to provide an adequate alternate forum. The outcome of this case will have implications on foreign policy, the extraterritorial reach of U.S. law, and the remedies available to the victims of Holocaust.

Questions as Framed for the Court by the Parties

Whether a district court may abstain from exercising jurisdiction under the Foreign Sovereign Immunities Act for reasons of international comity, in a matter in which former Hungarian nationals have sued the nation of Hungary to recover the value of property lost in Hungary during World War II but the plaintiffs made no attempt to exhaust local Hungarian remedies.

During World War II, Hungary undertook a systematic campaign to eradicate its Jewish population. Simon v. Republic of Hungary, (D.C. Cir. 2018) at 1175. As part of this campaign, the Hungarian government stripped Jews of their belongings. Id. Government officials went “home to home, inventorying and confiscating Jewish property.” Simon v.

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Sprint Communications Co. v. Jacobs

Issues

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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Facts

Petitioner Sprint Communications Company, L.P. (“Sprint”) connected Voice over Internet Protocol (“VoIP”) calls from Sprint’s to Windstream’s customers.Sprint Commc’n. Co., L.P. v. Jacobs, et al., 690 F.3d 864, 866 (8th Cir.

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T.M. v. University of Maryland Medical System Corp.

Issues

Does the Rooker-Feldman doctrine prohibit a plaintiff from challenging a state court judgment in federal court while an appeal in state court is still possible? 

The Supreme Court will decide whether the Rooker-Feldman doctrine applies to Petitioner T.M.’s case, wherein T.M. filed a claim in a federal court challenging a state court judgment before the state court judgment’s appeal window closed. T.M. argues that the Rooker-Feldman doctrine does not apply to her case because her state court judgment was not final or issued by the state’s highest court. If Rooker-Feldman applies to her case, T.M. asks the court to overturn the doctrine. Respondents, including the University of Maryland Medical System Corporation (“UMMS”), counter that the Rooker-Feldman doctrine should bar T.M.’s case because it meets all elements required by the doctrine. UMMS posits that any arguments that ask the Court to overturn Rooker-Feldman are beyond the scope of the question the Court has before it. The outcome of this case will have significant implications for litigation incentives and the relationship between federal and state courts.

Questions as Framed for the Court by the Parties

Whether the Rooker-Feldman doctrine, which prevents parties who lose in state courts from challenging injuries caused by state-court judgments, can be triggered by a state-court decision that remains subject to further review in state court.

The petitioner, whose identity has been anonymized to the initials “T.M.,” experienced a medical episode in 2023. T.M. v. University of Maryland Medical System Corporation at 3a. T.M.

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