Opinion · Supreme Court of the United States

Wilton v. Seven Falls Co.

515 U.S. 277

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1995-06-12
Topic
general

How later courts describe this case

  • holding that in declaratory judgment actions, district courts have “greater” discretion to abstain than under Colorado River’s “exceptional circumstances” test
  • holding that district court decisions on whether to exercise jurisdiction in declaratory judgment actions are subject only to abuse-of-discretion appellate review
  • holding that Brillhart governs the propriety of a district court’s decision to stay a declaratory judgment action
  • holding that a discretionary standard governs a district court's decision to stay a federal declaratory judgment action during the pendency of parallel state court proceedings
  • holding that review of district court declaratory judgment decisions is for abuse of discretion, not de novo
  • holding that the discretionary standard of Brillhart and not the "exceptional circumstances” standard of Colorado River applies to a district court’s decision to stay a declaratory judgment action
  • holding that district court did not abuse its discretion in staying declaratory judgment action pending outcome of parallel state proceeding
  • holding that the standard for determining whether to exercise such discretion to abstain is highly discretionary

Citator

UpLaw has not yet analyzed Wilton v. Seven Falls Co.. The absence of a flag is not a finding that it is good law.

Cited by
2488 opinions

Headnotes

  1. Civil Procedure — Declaratory Judgment The discretionary standard of Brillhart v. Excess Ins. Co. of America governs a district court's decision to stay a declaratory judgment action during the pendency of parallel state court proceedings, rather than the "exceptional circumstances" test of Colorado River and Moses H. Cone. 515 U.S. 277, 282-288 (1995)
  2. Civil Procedure — Declaratory Judgment District courts possess discretion in determining whether and when to entertain an action under the Declaratory Judgment Act, even when the suit otherwise satisfies subject matter jurisdictional prerequisites; in exercising that discretion, a court should examine the scope of the pending state court proceeding and the nature of defenses open there, including whether the claims of all parties in interest can satisfactorily be adjudicated in that proceeding, whether necessary parties have been joined, and whether such parties are amenable to process there. 515 U.S. 277, 282-283 (1995)
  3. Civil Procedure — Declaratory Judgment At least where another suit involving the same parties and presenting opportunity for ventilation of the same state law issues is pending in state court, a district court might be indulging in gratuitous interference if it permitted the federal declaratory action to proceed. 515 U.S. 277, 283 (1995)
  4. Civil Procedure — Declaratory Judgment The Declaratory Judgment Act's distinct features — including its textual commitment of discretion by providing that a court "may" declare the rights of litigants, and its repeated characterization as an enabling Act conferring discretion on the courts rather than an absolute right upon the litigant — justify a standard vesting district courts with greater discretion in declaratory judgment actions than that permitted under the "exceptional circumstances" test of Colorado River and Moses H. Cone, neither of which dealt with declaratory judgments. 515 U.S. 277, 283-287 (1995)
  5. Civil Procedure — Declaratory Judgment A district court is not required to proceed to the merits before staying or dismissing a declaratory judgment action; if a district court, in the sound exercise of its judgment, determines after a complaint is filed that a declaratory judgment will serve no useful purpose, it may stay or dismiss the action, and nothing in the Act requires the wasteful expenditure of judicial resources that hearing the case on the merits first would entail. 515 U.S. 277, 287-288 (1995)
  6. Civil Procedure — Declaratory Judgment District courts' decisions about the propriety of hearing declaratory judgment actions should be reviewed for abuse of discretion, not de novo, because facts bearing on the declaratory judgment remedy's usefulness and the case's fitness for resolution are particularly within the district courts' grasp, and proper application of the abuse of discretion standard on appeal can provide appropriate guidance to district courts. 515 U.S. 277, 288-289 (1995)
  7. Civil Procedure — Declaratory Judgment A district court acts within its bounds in staying a declaratory relief action where parallel proceedings, presenting opportunity for ventilation of the same state law issues, are underway in state court; where the basis for declining to proceed is the pendency of a state proceeding, a stay will often be the preferable course, because it assures that the federal action can proceed without risk of a time bar if the state case fails to resolve the matter in controversy. 515 U.S. 277, 289-290 (1995)