In Sprint Communications, Inc. v. Jacobs, the US Supreme Court unanimously held that the district court's abstention in deference to a parallel state-court proceeding was inappropriate (No. 12-815, (U.S. Dec. 10, 2013)).

Sprint, a national telecommunications service provider, challenged paying certain fees for Voice over Internet Protocol (VoIP) calls before the Iowa Utilities Board (IUB). Sprint argued that state regulation of VoIP calls was preempted by federal law. The IUB ruled against Sprint and found that intrastate fees applied.

Sprint then filed separate lawsuits against the IUB in both state and federal court. In both actions, Sprint sought a declaration that the Telecommunications Act of 1996 preempted the IUB's decision. The district court abstained based on the Supreme Court's holding in Younger v. Harris in deference to the parallel state-court proceeding (401 U.S. 37 (1971)). The US Court of Appeals for the Eighth Circuit affirmed.

The Supreme Court unanimously reversed and strictly defined the scope of the Younger abstention doctrine to three exceptional circumstances:

The Supreme Court specifically rejected the Eighth Circuit's broader approach, which would have required a Younger abstention whenever a parallel state judicial proceeding implicated important state interests and provided an adequate opportunity to raise federal challenges.

The court emphasized that once a federal court has jurisdiction over a case, it has an "unflagging" obligation to hear the case.

This decision makes clear that the Younger abstention doctrine applies in very limited circumstances to civil actions.