Colorado River Water Conservation District v. United States
Citation and Court
424 U.S. 800 (1976) — Supreme Court of the United States
Facts
The United States brought suit in federal district court to adjudicate water rights on behalf of certain Indian tribes in Colorado. At the same time, a comprehensive state water rights adjudication was pending in Colorado state court. The district court dismissed the federal action in deference to the parallel state proceeding.
Issue
Whether a federal court may dismiss or stay a federal action in deference to a concurrent state proceeding involving the same subject matter and parties.
Holding
Yes, but only in exceptional circumstances. Federal courts have a virtually unflagging obligation to exercise jurisdiction, but may abstain from concurrent proceedings in state court when a careful weighing of certain factors demonstrates that exceptional circumstances justify it.
Rule / Doctrine
Colorado River abstention: a federal court may defer to a concurrent state proceeding only in exceptional circumstances, assessed by considering factors including: (1) whether a court has assumed jurisdiction over property; (2) inconvenience of the federal forum; (3) desirability of avoiding piecemeal litigation; (4) the order in which jurisdiction was obtained; (5) whether federal or state law supplies the rule of decision; and (6) adequacy of the state forum to protect federal rights.
Significance
Colorado River created a narrow form of abstention distinct from the traditional Pullman, Burford, and Younger doctrines. It remains the governing framework for federal court deference to parallel (not prior) state proceedings, and is notable for its emphasis on the near-absolute duty of federal courts to exercise jurisdiction Congress has granted.