December 18, 2013
On December 10, 2013, the Supreme Court issued its decision in Sprint Communications Company v. Jacobs. The question in this case is whether the doctrine of Younger abstention--which requires that federal courts generally refrain from halting and supplanting state judicial proceedings--applies not only to state proceedings that are “coercive,” such as a state’s enforcement of its criminal laws, but also to state proceedings that are “remedial,” such as a state utility board’s order that Sprint pay certain intrastate access charges. In this case, the U.S. Court of Appeals for the Eighth Circuit had upheld a lower court ruling thatYounger abstention was appropriate.
The Supreme Court unanimously reversed the judgment of the Eighth Circuit. In an opinion authored by Justice Ginsburg, the Court held that the lower courts erred in abstaining under Younger, because the case did not fall within any of the three classes of exceptional cases for which Younger abstention was appropriate.
To discuss the case, we have Paul Salamanca, who is the Wyatt, Tarrant & Combs Professor of Law at the University of Kentucky College of Law. It should be noted that Professor Salamanca, along with a group of other Law Professors who teach and write on issues concerning federal courts, submitted an amicus brief in support of the petitioner.