Sprint Communications, Inc. v. Jacobs
134 S. Ct. 584
SCOTUS2013Background
- Sprint withheld intercarrier access fees for VoIP calls after concluding federal preemption; Windstream threatened to block calls.
- Sprint sought IUB relief to enjoin Windstream from discontinuing service, while Windstream argued the IUB proceeding should decide VoIP intrastate regulation.
- Sprint filed federal suit seeking preemption ruling and an injunction; Sprint also pursued state-court review asserting preemption and other claims.
- District Court abstained under Younger v. Harris in light of the parallel state proceeding; Eighth Circuit affirmed abstention.
- Iowa state court later addressed Sprint’s preemption claim; Sprint argued the dispute remained live and federal review was still appropriate.
- Court held that Younger abstention did not apply and that federal courts have jurisdiction to decide preemption claims in this context.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention applies here | Sprint argues parallel state proceeding warrants federal review. | IUB contends ongoing state review falls within Younger exceptions to abstention. | Younger abstention not required; federal jurisdiction retained. |
| Whether the IUB proceeding falls within NOPSI exceptions | Sprint contends proceeding is a federal-question preemption case not akin to enforcement. | IUB argues proceeding implicates state interests and enforcement-like characteristics. | IUB proceeding does not fit NOPSI exceptional categories; no abstention. |
| Whether federal courts have jurisdiction to decide preemption claims | Sprint asserts federal-question jurisdiction under 28 U.S.C. §1331 to review state action preemption. | IUB notes abstention could defer to state proceedings. | District Court had jurisdiction; abstention not warranted. |
Key Cases Cited
- Verizon Md. Inc. v. Pub. Serv. Comm’n of Md., 535 U.S. 635 (2002) (recognizes federal-question jurisdiction over state agency preemption)
- New Orleans Pub. Serv., Inc. v. Council of City of New Orleans, 491 U.S. 350 (1989) (NOPSI; exceptional Younger categories identified)
- Middlesex County Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (1982) ( Younger extension based on three conditions; cautions against broad application)
- Huffman v. Pursue, Ltd., 420 U.S. 592 (1975) (civil enforcement actions may warrant Younger abstention)
- Trainor v. Hernandez, 431 U.S. 434 (1977) (state-initiated action to sanction wrongful conduct; factors in Younger)
- Pennzoil Co. v. Texaco Inc., 481 U.S. 1 (1987) (state court orders and enforcement relevance to Younger)
- Juidice v. Vail, 430 U.S. 327 (1977) (civil proceedings involving state judicial processes)
- Colorado River Water Conservation Dist. v. United States, 424 U.S. 800 (1976) (general rule against unnecessary federal-state abstention; exception context)