## Facts

- Gulfstream Aerospace Corp. sued Mayacamas Corp. in Georgia state court for breach of an aircraft purchase contract.
- Mayacamas did not remove the Georgia case; about one month later it filed a diversity action in federal district court in California concerning the same contract.
- Gulfstream moved in the California federal case to stay or dismiss based on the earlier-filed Georgia state case, invoking Colorado River abstention.
- The district court denied the motion, concluding the circumstances were not exceptional enough to justify abstention.
- Gulfstream sought an interlocutory appeal; the Ninth Circuit dismissed for lack of appellate jurisdiction and declined mandamus relief.

## Issues

1. Whether an order denying a motion to stay or dismiss a federal action in favor of a parallel state action is immediately appealable as a “final decision” or collateral order under 28 U.S.C. § 1291.
2. Whether such an order is immediately appealable as an “injunction” under 28 U.S.C. § 1292(a)(1).
3. Whether the Enelow–Ettelson doctrine should continue to treat certain stay orders as appealable injunctions under § 1292(a)(1).

## Decision

- The Supreme Court unanimously affirmed the Ninth Circuit.
- The order denying a stay or dismissal in favor of a parallel state proceeding is not immediately appealable under § 1291.
- The order is not an appealable “injunction” under § 1292(a)(1) because it concerns management of the federal litigation’s course.
- The Court overruled the Enelow–Ettelson doctrine and held it should no longer be applied.

## Legal Principles

- A denial of a stay or dismissal sought on Colorado River (parallel-proceedings) grounds is not a “final decision” under § 1291 because it keeps the federal litigation moving forward.
- The collateral-order doctrine does not apply where the denial of a stay is inherently tentative and subject to reassessment as litigation develops.
- Orders that regulate only the conduct or progress of litigation in the district court are not “injunctions” for § 1292(a)(1) purposes.
- The Enelow–Ettelson doctrine is abolished; appealability of stay orders depends on the ordinary requirements of § 1291, § 1292, or other established avenues of review, not on historical law/equity labels.

## Conclusion

The Court held that a district court’s refusal to stay or dismiss a federal case in favor of a parallel state action is not immediately appealable under either § 1291 or § 1292(a)(1), and it eliminated the Enelow–Ettelson doctrine as a basis for interlocutory appellate jurisdiction.


Gulfstream Aerospace Corp. v. Mayacamas Corp., 485 U.S. 271 (1988)