United States Ninth Circuit

In a suit for breach of an auditing provision in a seed purchase contract, district court's dismissal of the action for lack of subject matter jurisdiction is reversed and remanded, as when a federal court evaluates realigning the parties in a case, it may not consider claims made in a different case. Here, the district court abused its discretion when it applied the incorrect rule, as it should not have declined to entertain the claim for declaratory relief under the Brillhart doctrine, rather than evaluating the claims under the Colorado River doctrine. Further, the district court abused its discretion in failing to find exceptional circumstances before declining to exercise its jurisdiction.

Appellate Information

• Decided 08/10/2012
• Published 08/10/2012

Judges

• Tashima

Court

• United States Ninth Circuit

Counsel