Quality One Wireless, LLC v. Goldie Group, LLC
2014 U.S. Dist. LEXIS 94410
| D. Mass. | 2014Background
- PCD sold cellular phones, accessories, and parts to Goldie Group from 1996–2013; Goldie Group allegedly owes about $2,134,384.88.
- PCD filed a Massachusetts state-court action against Goldie Group on February 20, 2013; Goldie Group answered and asserted counterclaims.
- PCD filed for Chapter 11 bankruptcy on August 19, 2013; PCD’s assets were sold to Quality One Wireless (Q1W) on October 17, 2013 and the debt was assigned to Q1W.
- PCD sought to substitute Q1W as plaintiff in the state action; state court denied substitution but allowed Q1W to be added as a plaintiff, which did not actually occur in the docket.
- On December 23, 2013, Q1W filed a federal complaint in this court seeking the same debt; Goldie Group moved to stay/dismiss and argued Q1W failed to join an indispensable party (PCD).
- Court granted motion to dismiss on the basis of the prior-pending-action doctrine and stayed the federal case; abstention under Colorado River was discussed but not reached as the case was stayed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the first-filed doctrine apply here? | Q1W argues the doctrine does not require dismissal or stay. | Goldie Group argues the doctrine favors staying in favor of the state action. | Not applicable; first-filed doctrine does not control. |
| Should the federal action be stayed or dismissed under the prior-pending-action doctrine? | Q1W argues against dismissal in favor of parallel actions. | Goldie Group argues to dismiss or stay the federal case, since state action is pending. | Applicable; stay permitted and federal action stayed. |
| Should the case be examined under the Colorado River abstention doctrine? | Q1W contends abstention not warranted given parallel actions. | Goldie Group argues balancing factors favors abstention. | Colorado River abstention discussed; stay deemed prudent; abstention not ministerial but stay is favored. |
| Is Q1W a proper party to the state-court action and does it affect dismissal? | Q1W seeks to proceed in federal court given assignment of debt. | State court did not substitute Q1W; potential indispensability of PCD. | Q1W not joined as a party in the state action; implications addressed but does not negate stay. |
Key Cases Cited
- Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (U.S. Supreme Court 1976) (abstention framework; exceptional circumstances required)
- Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1 (U.S. Supreme Court 1983) (wise judicial administration; parallel state actions)
- Jimenez v. Rodriguez-Pagan, 597 F.3d 18 (1st Cir. 2010) (parallel state and federal proceedings; abstention factors)
- Gonzalez v. Cruz, 926 F.2d 1 (1st Cir. 1991) (order of jurisdiction; forum considerations)
- KPS & Assocs., Inc. v. Designs by FMC, Inc., 318 F.3d 1 (1st Cir. 2003) (balance of factors; duplicative litigation considerations)