Alan Braid v. Oscar Stilley
22-2815
| 7th Cir. | Jul 21, 2025Background
- Dr. Alan Braid, a Texas OB/GYN, publicly admitted to performing an abortion in violation of the Texas Heartbeat Act (S.B. 8), prompting three individuals to sue him under the Act’s citizen-suit provision.
- S.B. 8 is unique: it empowers private individuals to enforce abortion restrictions via civil suits, rather than state officials, with a minimum of $10,000 in statutory damages per successful claim.
- Dr. Braid, to avoid duplicative and potentially conflicting liabilities, filed a federal interpleader and declaratory judgment action in Illinois, arguing for the unconstitutionality of S.B. 8.
- The district court dismissed the case, abstaining under the Wilton-Brillhart doctrine due to parallel state proceedings.
- On appeal, the Seventh Circuit determined the district court had jurisdiction under 28 U.S.C. § 1335 but affirmed dismissal, holding that Colorado River abstention also justified deferring to the Texas state courts.
- At the time of decision, only one state-court suit against Braid remained pending; others had been dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 1335 allow for interpleader in this context? | Braid: Federal interpleader is available due to risk of multiple liabilities under S.B. 8. | Stilley et al.: No specific or set fund exists; Braid’s liability is undetermined; $10,000 deposit is insufficient. | Yes; interpleader allowed, fund is sufficiently definite, and minimum statutory damages suffice. |
| Is the federal court required to hear the case (abstention)? | Braid: Abstention under Wilton-Brillhart doesn’t apply to statutory interpleader; federal courts are obligated to exercise jurisdiction. | Stilley et al.: Discretionary abstention is appropriate given parallel state proceedings, especially under Wilton-Brillhart or Colorado River. | Abstention is proper; even under Colorado River, exceptional circumstances exist for deferring to state courts. |
| Are the state and federal proceedings parallel? | Braid: Texas courts provide no fair forum, and there are additional claimants in federal court. | Stilley et al.: Differences don’t defeat parallelism; state courts can address Braid’s constitutional claims. | Yes; state proceedings are sufficiently parallel, despite minor differences in parties. |
| Should constitutional claims be resolved in federal court? | Braid: S.B. 8 is unconstitutional; federal courts should address constitutionality under First and Fourteenth Amendments. | Stilley et al.: State courts can decide statutory and constitutional issues first; federal review can follow. | State courts are better positioned to address novel state-law issues and related constitutional claims. |
Key Cases Cited
- Wilton v. Seven Falls Co., 515 U.S. 277 (1995) (district courts have discretion to abstain from declaratory judgment actions in favor of parallel state litigation)
- Brillhart v. Excess Ins. Co. of Am., 316 U.S. 491 (1942) (principles for discretionary abstention in federal declaratory suits)
- Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (1976) (sets the “exceptional circumstances” standard for abstention in parallel proceedings)
- Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (1983) (explains factors for federal abstention in light of state proceedings)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts have limited, statutorily conferred jurisdiction)
- State Farm Fire & Cas. Co. v. Tashire, 386 U.S. 523 (1967) (interpleader remedy available to interested stakeholders, not just disinterested ones)