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词条 Sprint Communications, Inc. v. Jacobs
释义

  1. Background

  2. Supreme Court

  3. See also

  4. References

  5. External links

{{refimprove|date=March 2016}}{{Infobox SCOTUS case
|Litigants=Sprint Communications, Inc. v. Jacobs
|ArgueDate=November 5
|ArgueYear=2013
|DecideDate=December 10
|DecideYear=2013
|FullName=Sprint Communications Inc., Petitioner v. Elizabeth S. Jacobs et al.
|USVol=571
|USPage=___
|ParallelCitations=134 S. Ct. 584; 187 L. Ed. 2d 505
|Docket=12-815
|OralArgument=https://www.oyez.org/cases/2010-2019/2013/2013_12_815/argument
|OpinionAnnouncement=
|Prior=690 F.3d [https://www.leagle.com/decision/infco20120904092 864] (8th Cir. 2012) (reversed)
|Subsequent=
|Holding=Federal court abstention under the Younger v. Harris doctrine is not in order simply because a pending state-court proceeding involves the same subject matter. Eighth Circuit reversed and remanded.
|SCOTUS=2010-2016
|Majority=Ginsburg
|JoinMajority=unanimous court
|LawsApplied=
}}Sprint Communications, Inc. v. Jacobs, 571 U.S. ___ (2013), was a decision by the United States Supreme Court in which a unanimous Court held that federal court abstention under the Younger v. Harris doctrine is not in order simply because a pending state-court proceeding involves the same subject matter.[1] The case involved a dispute between Sprint Corporation and Windstream Communications.[2][3]

Background

Sprint Corporation had paid Windstream Communications for certain long-distance calls from Sprint customers to Windstream customers in Iowa. In 2009, Sprint withheld payment for Voice over IP (VoIP) calls after concluding that the Telecommunications Act of 1996 pre-empted intrastate regulation of VoIP traffic. Windstream then threatened to block all calls to and from Sprint customers.{{cn|date=March 2016}}

In January 2010, Sprint filed a complaint with the Iowa Utilities Board (IUB) requesting a declaration that it was proper to withhold VoIP access charges.[4] Though Sprint settled the dispute with Windstream and withdrew the complaint, the board continued the proceeding so that it could decide the underlying issue of VoIP classification under federal law.{{cn|date=March 2016}}

In February 2011, the IUB issued an order with its own interpretation of VoIP’s classification under federal law along with a determination that Sprint was liable to Windstream for the access charges.[5] Sprint then filed suit against the board in both federal district court (seeking a declaration that the Telecommunications Act preempted the board's decision and seeking an injunction against enforcement) and state court (reiterating the preemption argument, and asserting state law and procedural due process claims).{{cn|date=March 2016}}

The federal district court dismissed the case because of the pending state suit and ruled that the Younger abstention applied.[6]{{better source|date=March 2016}} On appeal, the Eighth Circuit affirmed the abstention, vacated the dismissal, and remanded the case to the district court and ordered it enter a stay during the pendency of the state-court proceedings.[7]

Supreme Court

Justice Ginsburg delivered the opinion for a unanimous Court.{{cn|date=March 2016}}

In Younger v. Harris, {{ussc|401|37|1971}}, the Supreme Court ruled that federal courts are required to abstain from hearing any civil rights tort claims brought by a person who is currently being prosecuted for a matter arising from that claim (the Younger abstention). The Court also recognized three exceptions to this abstention: 1) where the prosecution is in bad faith; 2) where the prosecution is part of some pattern of harassment against an individual; 3) or where the law being enforced is utterly and irredeemably unconstitutional.

The Court ruled that none of the three exemptions to the Younger abstention apply in this case. Federal courts "are obliged to decide cases within the scope of federal jurisdiction" and "[a]bstention is not in order simply because a pending state-court proceeding involves the same subject matter."{{cn|date=March 2016}}

After the decision, the Eighth Circuit vacated its earlier opinion, reversed the district court, and remanded the case to the district court for further proceedings.[7]

See also

  • Verizon Communications Inc. v. Federal Communications Commission (2002)

References

1. ^[https://www.supremecourt.gov/opinions/13pdf/12-815_qol1.pdf Sprint Communications Co. v. Jacobs], {{ussc|571|___|2013}}
2. ^[https://www.oyez.org/cases/2010-2019/2013/2013_12_815 The Oyez Project: Sprint Communications Co v. Jacobs]
3. ^SCOTUSblog: Sprint Communications Company v. Jacobs
4. ^[https://efs.iowa.gov/cs/groups/external/documents/docket/mdaw/mdu0/~edisp/030034.pdf Iowa Utilities Board: Sprint vs. Iowa Telecom. Complaint and Request for Emergency Relief]
5. ^[https://efs.iowa.gov/cs/groups/external/documents/docket/mdaw/mdc0/~edisp/058553.pdf Iowa Utilities Board: Sprint vs. Iowa Telecom. Order]
6. ^Sprint v. IUB 4:11-cv-00183-JAJ
7. ^{{cite court |litigants=Sprint Communications, Inc. v. Jacobs |vol=690 |reporter=F.3d |opinion=864 |pinpoint= |court=8th Cir. |date=2012 |url=https://www.leagle.com/decision/infco20120904092 |accessdate=2018-09-18 |quote=}}

External links

  • {{caselaw source

| case = Sprint Communications, Inc. v. Jacobs, {{ussc|571|___|2013|el=no}}
| justia =https://supreme.justia.com/cases/federal/us/571/12-815/
| oyez =https://www.oyez.org/cases/2013/12-815
| other_source1 = Supreme Court (slip opinion)
| other_url1 =https://www.supremecourt.gov/opinions/13pdf/12-815_qol1.pdf{{Sprint}}

6 : United States Supreme Court cases|United States Supreme Court cases of the Roberts Court|2013 in United States case law|Sprint Corporation|United States federal jurisdiction case law|United States communications regulation case law

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