## Facts

- Sprint Communications withheld payment of intercarrier access charges assessed by Windstream for long-distance Voice over Internet Protocol (VoIP) calls, asserting that federal law preempted intrastate regulation of VoIP traffic.
- Windstream threatened to block Sprint customer calls, prompting Sprint to file a complaint with the Iowa Utilities Board (IUB) seeking to prevent service discontinuation.
- After Windstream retracted its threat, Sprint sought to withdraw its administrative complaint, but the IUB continued the proceeding to decide whether intrastate access charges applied to VoIP calls.
- The IUB rejected Sprint’s federal preemption position and ruled that intrastate fees applied to VoIP calls and Sprint was liable for those charges.
- Sprint challenged the IUB order in two forums: (1) a federal action against IUB members seeking declaratory and injunctive relief on preemption grounds, and (2) a state-court petition for judicial review of the IUB order raising preemption and other claims.
- The federal district court abstained under Younger and dismissed the federal case; the Eighth Circuit affirmed abstention but directed that the federal action be stayed rather than dismissed.

## Issues

1. Whether Younger abstention requires a federal court to decline jurisdiction merely because a related state-court proceeding is pending and involves the same subject matter.
2. Whether state-court judicial review of a state utility board order in a private dispute qualifies as a Younger-covered proceeding (criminal, quasi-criminal civil enforcement, or a proceeding uniquely tied to a state court’s ability to perform judicial functions).

## Decision

- The Supreme Court unanimously reversed the Eighth Circuit and remanded.
- The Court held that Younger abstention was not warranted because the state proceedings did not fit within any recognized category triggering Younger.
- The Court ruled that a federal court must exercise jurisdiction over Sprint’s federal preemption claims; subject-matter overlap with a pending state proceeding is insufficient to justify abstention.

## Legal Principles

- Federal courts have a “virtually unflagging obligation” to exercise the jurisdiction conferred on them; abstention is the exception.
- Younger abstention is limited to three categories of state proceedings: (1) ongoing criminal prosecutions, (2) certain quasi-criminal civil enforcement proceedings, and (3) civil proceedings involving orders uniquely in furtherance of state courts’ ability to perform their judicial functions.
- The three-category description of Younger’s reach is exhaustive; Younger does not apply based on a free-standing “important state interest” or mere parallel litigation.
- A state administrative proceeding initiated to address a private commercial dispute, and subsequent state-court review of that administrative decision, is not automatically a quasi-criminal enforcement action for Younger purposes.

## Conclusion

The Court confined Younger abstention to three defined classes of state proceedings and held that federal courts may not decline jurisdiction simply because a parallel state case concerning the same regulatory subject matter is pending.


Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (2013)