''Sprint Communications, Inc. v. Jacobs'', 571 U.S. 69 (2013), was a decision by the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on question ...

in which a unanimous Court held that federal court abstention under the '' Younger v. Harris'' doctrine is not in order simply because a pending state-court proceeding involves the same subject matter.''Sprint Communications Co. v. Jacobs''
The case involved a dispute between

Sprint Corporation Sprint Corporation was an American telecommunications company. Before being acquired by T-Mobile US on April 1, 2020, it was the fourth-largest mobile network operator in the United States, serving 54.3 million customers as of June 30, 2019. Th ...

and

Windstream Communications Windstream Holdings, Inc., trading as Windstream Communications is a provider of voice and data network communications to businesses across the United States. Under the Kinetic brand, it offers broadband, phone and digital streaming TV services to ...

.The Oyez Project: ''Sprint Communications Co v. Jacobs''
/ref>SCOTUSblog: Sprint Communications Company v. Jacobs
/ref>

Background

had paid

for certain long-distance calls from Sprint customers to Windstream customers in Iowa. In 2009, Sprint withheld payment for

Voice over IP Voice over Internet Protocol (VoIP), also known as IP telephony, is a set of technologies used primarily for voice communication sessions over Internet Protocol (IP) networks, such as the Internet. VoIP enables voice calls to be transmitted as ...

(VoIP) calls after concluding that the

Telecommunications Act of 1996 The Telecommunications Act of 1996 is a United States federal law enacted by the 104th United States Congress on January 3, 1996, and signed into law on February 8, 1996, by President Bill Clinton. It primarily amended Chapter 5 of Title 47 of ...

pre-empted intrastate regulation of VoIP traffic. Windstream then threatened to block all calls to and from Sprint customers. In January 2010, Sprint filed a complaint with the

Iowa Utilities Board The Iowa Utilities Board (IUB) is a three-member public utilities commission, with beginnings in 1878. It is a quasi-judicial tribunal, which regulates services and rates of electric, natural gas, water and telecommunication providers, as well as a ...

(IUB) requesting a declaration that it was proper to withhold VoIP access charges. Though Sprint settled the dispute with Windstream and withdrew the complaint, the board continued the proceeding so that it could decide the underlying issue of VoIP classification under federal law. In February 2011, the IUB issued an order with its own interpretation of VoIP’s classification under federal law along with a determination that Sprint was liable to Windstream for the access charges. Sprint then filed suit against the board in both

federal district court The United States district courts are the trial courts of the U.S. federal judiciary. There is one district court for each federal judicial district. Each district covers one U.S. state or a portion of a state. There is at least one feder ...

(seeking a declaration that the Telecommunications Act preempted the board's decision and seeking an injunction against enforcement) and state court (reiterating the preemption argument, and asserting state law and procedural due process claims). The federal district court dismissed the case because of the pending state suit and ruled that the ''Younger'' abstention applied.Sprint v. IUB 4:11-cv-00183-JAJ
/ref> On appeal, the Eighth Circuit affirmed the abstention, vacated the dismissal, and remanded the case to the district court and ordered it enter a stay during the pendency of the state-court proceedings.

Supreme Court

Justice Ginsburg delivered the opinion for a unanimous Court. In '' Younger v. Harris'', , the Supreme Court ruled 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 (the ''Younger'' abstention). The Court also recognized three exceptions to this abstention: 1) where the prosecution is in bad faith; 2) where the prosecution is part of some pattern of harassment against an individual; 3) or where the law being enforced is utterly and irredeemably unconstitutional. The Court ruled that none of the three exemptions to the ''Younger'' abstention apply in this case. Federal courts "are obliged to decide cases within the scope of federal jurisdiction" and " stention is not in order simply because a pending state-court proceeding involves the same subject matter." After the decision, the Eighth Circuit vacated its earlier opinion, reversed the

district court District courts are a category of courts which exists in several nations, some call them "small case court" usually as the lowest level of the hierarchy. These courts generally work under a higher court which exercises control over the lower co ...

, and remanded the case to the district court for further proceedings.

References

External links

* {{Sprint United States Supreme Court cases United States Supreme Court cases of the Roberts Court 2013 in United States case law Sprint Corporation United States federal jurisdiction case law United States communications regulation case law

Background

Supreme Court

See also

References

External links