United States Fourth Circuit

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vonRosenberg v. Lawrence, 14-1122

In this dispute between two clergymen, each who believes himself to be the proper leader of the Protestant Episcopal Church in the Diocese of South Carolina, plaintiff alleged two Lanham Act violations and sought declaratory and nondeclaratory relief. In response, defendant asked the district court to abstain in favor of pending related state court proceedings. The district court stayed the action pursuant to the abstention doctrine articulated in Brillhart v. Excess Insurance Co. of America and Wilton v. Seven Falls Co., each of which grant a federal court broad discretion to stay declaratory judgment actions. The stay order is vacated and the case is remanded for further proceedings, where Colorado River Water Conservation District v. United States, which permits a federal court to abstain only in "exceptional" circumstances, properly governs the abstention decision in this action.

Appellate Information

  • Decided 03/31/2015
  • Published 03/31/2015

Judges

  • Motz

Court

  • United States Fourth Circuit

Counsel