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5:13-cv-04100
N.D. Iowa
Oct 27, 2014
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Background

  • Plaintiffs (Dordt College and Cornerstone University) obtained a preliminary injunction on June 26, 2014, enjoining enforcement of an HHS regulatory scheme relating to ACA preventive-services coverage.
  • Defendants (HHS Secretary et al.) appealed the preliminary injunction to the Eighth Circuit; oral argument was scheduled for December 2014.
  • The district court had reserved ruling on defendants’ dispositive motion and ordered supplemental briefing by October 29, 2014, in light of Wheaton College v. Burwell and interim HHS regulations.
  • Defendants moved (unopposed by plaintiffs) to stay all district-court proceedings pending resolution of the appeal.
  • The court applied the standard stay factors (prejudice to non-moving party; whether stay will simplify issues; status of discovery/trial setting) and concluded a stay best served judicial economy and efficiency.
  • The court granted the stay, requiring the parties to notify the court within 15 days after the appeal concludes about further proceedings.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether to stay district-court proceedings pending the Eighth Circuit appeal Plaintiffs did not oppose a stay Stay avoids duplicative litigation and preserves resources while appeal resolves key issues Granted: proceedings stayed pending appeal or further order
Whether a stay would prejudice plaintiffs Plaintiffs asserted no prejudice (did not oppose) Defendants asserted no undue prejudice; appeal imminent Court found no undue prejudice given plaintiffs’ consent and pending appeal
Whether the appeal will simplify or resolve district issues Plaintiffs implicitly agreed stay appropriate because appeal likely dispositive Defendants argued the appeal will address merits (e.g., RFRA likelihood) and overlap with district issues Court found stay likely to simplify/resolve issues and avoid duplication
Whether case posture favors a stay (discovery/trial readiness) Plaintiffs noted case not at trial; earlier litigation costs incurred Defendants noted no trial date and that further district work would be wasteful Court found case not so advanced as to preclude a stay and favored economy of resources

Key Cases Cited

  • Landis v. North American Co., 299 U.S. 248 (1936) (district courts have inherent power to stay proceedings for docket and resource economy)
  • Mediterranean Enterprises, Inc. v. Ssangyong Corp., 708 F.2d 1458 (9th Cir. 1983) (stays appropriate where independent proceedings will materially affect the case)
  • Wheaton College v. Burwell, 134 S. Ct. 2806 (2014) (Supreme Court interim action relevant to regulatory landscape and supplemental briefing)
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Case Details

Case Name: Dordt College v. Azar II
Court Name: District Court, N.D. Iowa
Date Published: Oct 27, 2014
Citation: 5:13-cv-04100
Docket Number: 5:13-cv-04100
Court Abbreviation: N.D. Iowa
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