First Circuit Elucidates Reformulated Abstention Doctrine | Practical Law

First Circuit Elucidates Reformulated Abstention Doctrine | Practical Law

In Sirva Relocation, LLC v. Richie, the US Court of Appeals for the First Circuit held that abstention was required with regard to a state commission proceeding. This was the first case in the First Circuit to address the US Supreme Court's abstention doctrine as set out in Younger v. Harris and reformulated by its recent Sprint Communications, Inc. v. Jacobs decision.

First Circuit Elucidates Reformulated Abstention Doctrine

Practical Law Legal Update w-000-4792 (Approx. 3 pages)

First Circuit Elucidates Reformulated Abstention Doctrine

by Practical Law Litigation
Published on 21 Jul 2015 • USA (National/Federal)
In Sirva Relocation, LLC v. Richie, the US Court of Appeals for the First Circuit held that abstention was required with regard to a state commission proceeding. This was the first case in the First Circuit to address the US Supreme Court's abstention doctrine as set out in Younger v. Harris and reformulated by its recent Sprint Communications, Inc. v. Jacobs decision.
In a July 20, 2015 decision, Sirva Relocation, LLC v. Richie, 794 F.3d 185 (1st Cir. 2015)), the US Court of Appeals for the First Circuit considered for the first time the US Supreme Court's abstention doctrine set out in Younger v. Harris (401 U.S. 37 (1971)) and subsequently modified by Sprint Communications, Inc. v. Jacobs (134 S.Ct. 584 (2013)). The First Circuit held that abstention was required with regard to a state commission proceeding.
Sirva, a moving and housing solutions company, offered its employees disability insurance underwritten by Aetna. David Knight, a Sirva employee, began receiving disability benefits due to mental illness. When Knight exhausted his benefits and his payments were terminated, Knight filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD). Almost six years after the commencement of the MCAD proceeding, the MCAD scheduled a public hearing on the matter. Sirva and Aetna filed a complaint in the US District Court for the District of Massachusetts asking the court to enjoin the MCAD proceeding. The MCAD and Knight moved to dismiss the complaint and asked the court to abstain from hearing the case.
While the case was pending, the US Supreme Court decided Sprint, which narrowed the scope of the abstention doctrine enunciated in Younger. The district court, after ordering supplemental briefing and hearing oral arguments, ruled that abstention was required and dismissed the appeal. Sirva and Aetna appealed.
The First Circuit affirmed the district court's decision to abstain. In reaching its decision, the court tracked the evolution of the Younger abstention doctrine, which requires federal courts to refrain from interfering with certain state proceedings in the absence of extraordinary circumstances. The court noted that the US Supreme Court articulated three factors for determining when a federal court must abstain under Younger: when (1) there is an ongoing state proceeding that is judicial in nature, which (2) implicates important state interests and (3) provides an adequate opportunity to raise federal defenses (Middlesex County Ethics Committee v. Garden State Bar Ass'n, 457 U.S. 423 (1982)). The court further acknowledged that the US Supreme Court in Sprint limited Younger abstention to only criminal prosecutions, civil proceedings that are akin to criminal prosecutions, and proceedings that implicate a state's interest in enforcing the orders and judgments of its courts.
The First Circuit distilled a three-step approach to the reformulated Younger abstention analysis:
  • First, a federal court must ascertain whether a particular state proceeding falls within the Younger taxonomy articulated in Sprint.
  • If yes, the court must then consider whether the Middlesex factors support abstention.
  • If these two steps leave the case on track for abstention, the court must then determine whether any of the following exceptions to the Younger doctrine apply:
    • the state proceeding is brought in bad faith;
    • the state forum provides inadequate protection of federal rights; or
    • the state statute in question violates express constitutional prohibitions.
Applying this three-step approach, the First Circuit held that abstention was appropriate and that no exception to abstention applied, and affirmed dismissal.