Supreme Court of the United States · Official docket →
Mendocino Railway, a California Corporation v. Kate Huckelbridge, Executive Director, California Coastal Commission, et al.
Paid petition · United States Court of Appeals for the Ninth Circuit, No. 23-15857 · judgment August 29, 2024
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Question presented
Under Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976), a district court can abstain from a federal case in deference to a parallel state-court action only in “exceptional circumstances” and with “the clearest of justifications.” But the lower courts’ application of the doctrine has been a story of confusion and unpredictability. The doctrine has even been described as “dangerous, unprincipled, and unfair,” and in tension with the separation of powers,1 because lower courts have too-easily abdicated their “virtually unflagging obligation” to “exercise the jurisdiction given them” based on the weighing of vague and subjective factors that differ across circuits. Id. at 817. The Ninth Circuit’s published decision in this case exemplifies the problems with Colorado River. The court here dismissed Petitioner’s federal-preemption claims based on a later-filed state-court action, after weighing factors that other circuit courts either don’t weigh or weigh very differently. Petitioner’s claims would have survived in those circuits. The circuit conflict over Colorado River, which evidences the doctrine’s growing unworkability, cries out for review. The questions presented are: 1. Whether the Court should abrogate Colorado River’s abstention doctrine. 1 Linda S. Mullenix, A Branch Too Far: Pruning the Abstention Doctrine, 75 Geo. L.J. 99, 103 (1986).
Counsel of record
For petitioner
Paul J. Beard II
Pierson Ferdinand
For respondent
Krista MacNevin Jee
Jones & Mayer
Case
Conference history
Distributed for 2 conferences
Amicus briefs
2 cert-stage
Proceedings
- Oct 06 2025Petition DENIED.
- Aug 06 2025DISTRIBUTED for Conference of 9/29/2025.
- Jul 30 2025Reply of petitioner Mendocino Railway filed.
- Jul 16 2025Brief of respondent Fort Bragg, California, in opposition filed.
- Jul 16 2025Brief of respondent Kate Huckelbridge, Executive Director, California Coastal Commission in opposition filed. (Distributed)
- Jun 12 2025Motion to extend the time to file a response is granted and the time is extended to and including July 16, 2025, for all respondents.
- Jun 11 2025Motion of respondent City of Fort Bragg to extend the time to file a response from June 16, 2025 to July 16, 2025, submitted to The Clerk.
- Jun 04 2025Motion to extend the time to file a response is granted and the time is extended to and including July 16, 2025.
- Jun 03 2025Motion to extend the time to file a response from June 16, 2025 to July 16, 2025, submitted to The Clerk.
- May 15 2025Response Requested. (Due June 16, 2025)
- Apr 29 2025DISTRIBUTED for Conference of 5/15/2025.
- Apr 14 2025Brief amicus curiae of Western Manufactured Housing Communities Association filed.
- Apr 14 2025Brief amicus curiae of Pacific Legal Foundation filed.
- Mar 28 2025Waiver of right of respondent Jack Ainsworth, in his official capacity as Executive Director of the California Coastal Commission to respond filed.
- Mar 10 2025Petition for a writ of certiorari filed. (Response due April 14, 2025)