Sprint Commc'ns, Inc. v. Jacobs
571 U.S. 69
| SCOTUS | 2013Background
- Two parallel proceedings—one in state court, one in federal court—challenged an Iowa Utilities Board (IUB) order allowing Windstream to charge intrastate access fees for VoIP calls routed via the Internet.
- Sprint paid Windstream historically but withheld VoIP-related intrastate fees in 2009, arguing federal preemption under the Telecommunications Act of 1996, triggering IUB review.
- IUB continued the proceeding to resolve whether VoIP calls are intrastate-regulated, ruling in Windstream’s favor that intrastate fees apply.
- Sprint filed a federal suit seeking preemption-based relief and an injunction, and a state-court petition for review, arguing federal preemption and state-law due-process claims.
- The federal district court abstained under Younger, citing a parallel state proceeding and the belief that the case involved important state interests; Eighth Circuit affirmed abstention and remanded with a stay, prompting Supreme Court review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention was appropriate | Sprint argues ongoing state proceedings implicate federal challenges and require merits review. | IUB contends the initial adjudication is an ongoing unitary process that justifies abstention. | Younger abstention not appropriate; federal merits review allowed. |
| Whether the IUB proceeding fits any Younger exception | Sprint contends the proceeding is a civil enforcement or state-initiated action. | IUB argues the proceeding is not coercive enforcement nor state-initiated. | Not within the three exceptional categories; abstention rejected. |
| Whether federal preemption claim is within federal-question jurisdiction | Sprint maintains federal law preempts Iowa intrastate regulation of VoIP. | Windstream/IUB argue state processes are proper fora for review notwithstanding preemption questions. | Federal-question jurisdiction exists; merits review allowed. |
| Whether the case should be dismissed or stayed pending state proceedings | Sprint seeks federal resolution regardless of state review. | IUB urged staying or abstaining until state review concludes. | Court does not adopt abstention or stay; proceeds to merits. |
| Whether the IUB order itself is properly reviewable in federal court | Sprint asserts federal preemption affects the IUB order’s validity. | IUB maintains state-court review suffices. | Federal review of the preemption issue is proper. |
Key Cases Cited
- New Orleans Public Service, Inc. v. Council of City of New Orleans, 491 U.S. 350 (1989) (NOPSI; establishes exceptional Younger categories but not blanket abstention)
- Verizon Md. Inc. v. Pub. Serv. Comm’n of Md., 535 U.S. 635 (2002) (recognizes federal-question jurisdiction over preemption challenges to state actions)
- Middlesex County Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (1982) (three-factor test; exceptional Younger extension discussed)
- Huffman v. Pursue, Ltd., 420 U.S. 592 (1975) (state civil enforcement akin to criminal action for Younger abstention)
- Trainor v. Hernandez, 431 U.S. 434 (1977) (state proceedings brought by sovereign to enforce rules; quasi-criminal context)
- Pennzoil Co. v. Texaco Inc., 481 U.S. 1 (1987) (state actions and respect for state court processes; part of Younger framework)
- Juidice v. Vail, 430 U.S. 327 (1977) (civil contempt/proceedings; handling of state functions in federal litigation)
- Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (1976) (primary rule on federal abstention when parallel proceedings exist)