Wilton v. Seven Falls Company (1994)
- Docket
- 94-562
- Decided
- 1994-01-01
Summary
Question: Does the exceptional circumstances test govern a district court's decision to stay a declaratory judgment action during the pendency of parallel state court proceedings? Should a court of appeals evaluate a district court's decision to do so under an abuse of discretion standard of review? Conclusion: No and yes. In a 8-0 opinion delivered by Justice Sandra Day O'Connor, the Court held that the discretionary standard of Brillhart v. Excess Ins. Co. of America, 316 U.S. 491, governs a district court's decision to stay a declaratory judgment action during the pendency of parallel state court proceedings and that a district courts' decisions about the propriety of hearing declaratory judgment actions should be reviewed for abuse of discretion. The Court also concluded that the District Court acted within its bounds in staying the declaratory relief action in this case, since parallel proceedings, presenting an opportunity for the ventilation of the same state law issues, were underway in state court. Justice Stephen G. Breyer did not participate.