Decided: March 31, 2015
The Fourth Circuit held that in considering whether to abstain in cases where a plaintiff seeks both declaratory and nondeclaratory relief, a federal court’s task is to determine whether exceptional circumstances justify surrendering jurisdiction.
This appeal arises from a dispute between two clergymen who each believe himself to be the leader of the Protestant Episcopal Church (the “Church”) in the Diocese of South Carolina. Bishop Mark Lawrence (“Lawrence”) was allegedly ousted from his position as Bishop of the Dioscese of South Carolina in December 2012. Bishop Charles VonRosenberg (“VonRosenberg”) was elected and installed by a Convention of the Diocese to be Lawrence’s replacement. On January 4, 2013, Lawrence filed suit in South Carolina alleging service mark infringement and improper use of names, styles, and emblems under state law. VonRosenberg subsequently filed the present action seeking declaratory and injunctive relief, alleging that Lawrence improperly continued to use the Church’s service marks and falsely advertised himself as leader of the Church after he had been replaced, in violation of the Lanham Act, 15 U.S.C. §§ 1114, 1125(a)(1)(A) (2012). Lawrence asked the District Court to abstain in favor of the pending state court proceedings. The District Court of South Carolina granted Lawrence’s motion to abstain, relying on doctrine articulated in Brillhart v. Excess Insurance Co. of America, 316 U.S. 491 (1942) which gives courts “broad discretion to … decline to grant declaratory relief”.
The Fourth Circuit ultimately concluded that the district court had used the wrong standard when it decided to abstain. The Brillhart/Wilton standard used by the district court gives federal courts broad discretion to abstain from deciding declaratory judgment actions when concurrent state proceedings are underway. The Fourth Circuit noted that it had never expressly held which abstention standard applies to a federal complaint, like VonRosenberg’s, which asserts claims for declaratory and nondeclaratory relief. The Fourth Circuit rejected the Brillhart/Wilton standard in mixed cases because it would “deprive a plaintiff of access to a federal forum simply because he sought declaratory relief in addition to an injunction or money damages.” Ultimately, the Court adopted the Colorado River standard for all cases where a plaintiff seeks declaratory and nondeclaratory relief. The Colorado River standard states that a federal court’s task is to “ascertain whether there exists ‘exceptional’ circumstances . . . to justify the surrender of [federal] jurisdiction.” Colorado River Water Conservation District v. United States, 424 U.800, 813 (1976). The Court further stated that the only exception to the standard arises when a party’s request for the nondeclaratory relief is frivolous or only made to avoid the Brillhart standard. Because the district court did not apply the Colorado River standard, the Fourth Circuit vacated the District Court’s decision and remanded for further proceedings consistent with its opinion.