In Sprint Communications, Inc. v. Jacobs, 134 S. Ct. 584 (U.S. 2013) (No. 12-815), Sprint filed a complaint with the Iowa Utilities Board (the “IUB”), contesting access fees that a local telecommunications carrier was charging Sprint for calls made via the internet. After the IUB ruled that such fees were permissible, Sprint filed two lawsuits, one in state court and one in federal court, seeking to overturn the IUB’s ruling. At the urging of the IUB, the federal district court abstained from hearing the matter, holding that the Younger abstention doctrine announced by the Supreme Court in Younger v. Harris, 401 U.S. 37 (1971), required abstention in light of the ongoing state judicial proceeding. The Eighth Circuit agreed that abstention was required, but vacated the dismissal of the complaint and instead entered a stay during the pendency of the state court action. The Supreme Court reversed, holding that abstention was not warranted. The Court reiterated that the general rule is that abstention is disfavored, and is not in order simply because a pending state court proceeding involves the same subject matter – even if it implicates important state interests. The Court clarified that the exception it recognized in Younger and its progeny is a narrow one and is limited to “three exceptional categories” of proceedings: state criminal prosecutions, civil enforcement proceedings, and civil proceedings involving certain orders that are uniquely in furtherance of the state courts’ ability to perform their judicial functions. Because this matter did not fall within any of those categories, the district court was required to hear and decide the case.