Seneca Insurance Co. v. Strange Land, Inc.

The Ninth Circuit vacated the district court's order staying Seneca's action against Strange Land in a parallel state court proceeding. The panel held that the district court correctly chose to analyze the abstention motion under the Colorado River framework where Seneca sought remedies beyond declaratory judgment. Applying the factors in assessing the appropriateness of a Colorado River stay, the panel held that the district court abused its narrow discretion, essentially transforming the strong presumption against abstention into a presumption in favor of abstention where state law issues predominate. The panel explained that nothing about this case was "exceptional" so as to warrant disregarding the "virtually unflagging obligation" of a federal court to exercise its jurisdiction. Accordingly, the panel remanded. View "Seneca Insurance Co. v. Strange Land, Inc." on Justia Law