Central Telephone Co. v. Sprint Communications Co. of Virginia, Inc., 715 F.3d 501

Sprint and CenturyLink entered into 19 interconnection agreements (ICAs) governing traffic exchange after the 1996 Act's framework.
Sprint withheld payments for VoIP traffic, challenging the ICA’s application and rate structure, including VoIP over FGD trunks.
CenturyLink sued in federal court for breach of contract; Sprint counterclaimed over local vs. nonlocal VoIP charges under NC ICA.
District court held jurisdiction under the 1996 Act, rejected Sprint’s exhaustion/primary jurisdiction defense, and ruled in CenturyLink’s favor on the breach claim.
During post-trial disclosures, the district judge discovered he owned CenturyLink shares in a managed IRA; the judge divested and a recusal/recusal-vacatur dispute followed on appeal.
On appeal, the Fourth Circuit affirmed the district court, addressing federal jurisdiction, recusal, and contract-interpretation under Virginia and North Carolina law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
District court authority under 1996 Act to interpret ICAs	Sprint: district court cannot interpret/enforce ICAs absent State commission	CenturyLink: court has jurisdiction under §1331 and §252(e)(6); no exhaustion required	District court had authority to decide merits
Whether exhaustion or state-first review is required	Sprint: require initial State commission consideration/exhaustion	CenturyLink: no exhaustion requirement under statute or Starpower rationale	No mandatory exhaustion; district court may decide merits
Whether ICA applies to VoIP traffic over FGD trunks	Sprint: §38.4 does not cover VoIP over FGD trunks; exclude such traffic from ICA	CenturyLink: ICA §38.4 applies to VoIP traffic; ambiguous coverage resolved against drafter	ICA applies to VoIP over FGD trunks; CenturyLink prevails on breach
CenturyLink counterclaim: BTN vs CPN method for local vs nonlocal calls	Sprint: NC ICA requires CPN; BTN misclassifies local calls as nonlocal	CenturyLink: NC ICA permits BTN per Telcordia GR-1100-CORE; proper under‑bilateral agreement	BTN method permitted; CenturyLink validly billed as nonlocal where appropriate

Verizon, M.D. v. Public Serv. Comm’n of Maryland, 535 U.S. 635 (2002) (federal jurisdiction over interconnection-related issues)
Core Commc’ns, Inc. v. Verizon Pa., Inc., 493 F.3d 333 (3d Cir. 2007) (State commissions have authority to interpret/enforce ICAs; post-formation disputes)
Sw. Bell Tel., L.P. v. Pub. Util. Comm’n, 467 F.3d 418 (5th Cir. 2006) (state commissions’ role in ICAs under §252(e)(6))
E.SPIRE Commc’ns, Inc. v. N.M. Pub. Regulation Comm’n, 392 F.3d 1204 (10th Cir. 2004) (state agency responsibility in ICA interpretation)
Iowa Network Servs., Inc. v. Qwest Corp., 363 F.3d 683 (8th Cir. 2004) (statutory framework and state/federal roles in ICAs)
BellSouth Telecomms., Inc. v. MCImetro Access Transmission Servs., Inc., 317 F.3d 1270 (11th Cir. 2003) (en banc; state commission authority in ICA interpretation)
MCI Telecomms. Corp. v. Ill. Bell Tel. Co., 222 F.3d 323 (7th Cir. 2000) (interpretation/enforcement of ICAs)
Starpower Communications, LLC, 15 F.C.C.R. 11277 (FCC 2000) (state commissions’ responsibility to interpret/enforce ICAs when asked)
Hart v. New York City Development Corp., 796 F.2d 976 (7th Cir. 1986) (safe harbor for investments through common investment funds)
Cavalier Tel., LLC v. Va. Electric & Power Co., 303 F.3d 316 (4th Cir. 2002) (exhaustion and jurisdiction considerations under 1996 Act)