Law School Case Brief
Colo. River Water Conservation Dist. v. United States - 424 U.S. 800, 96 S. Ct. 1236 (1976)
Generally, as between state and federal courts, the rule is that the pendency of an action in the state court is no bar to proceedings concerning the same matter in the federal court having jurisdiction. As between federal district courts, however, though no precise rule has evolved, the general principle is to avoid duplicative litigation. That difference in general approach between state-federal concurrent jurisdiction and wholly federal concurrent jurisdiction stems from the virtually unflagging obligation of the federal courts to exercise the jurisdiction given them. Given that obligation, and the absence of weightier considerations of constitutional adjudication and state-federal relations, the circumstances permitting the dismissal of a federal suit due to the presence of a concurrent state proceeding for reasons of wise judicial administration are considerably more limited than the circumstances appropriate for abstention. The former circumstances, though exceptional, do nevertheless exist.
In order to manage the allocation of water and to resolve conflicting claims thereto, Colorado enacted legislation under which the state was divided into seven Water Divisions, in each of which a procedure was established for the settlement of water claims on a continuous basis. A state engineer was charged with responsibility for administering the distribution of state waters. Seeking adjudication of reserved rights claimed on behalf of itself and certain Indian tribes, as well as rights based on state law, in waters in certain rivers in Division 7, the United States brought a suit against some 1,000 water users in a federal district court. The Government invoked jurisdiction under 28 U.S.C.S. § 1345. Shortly thereafter, one of the federal-suit defendants sought in a state court for Division 7 to make the Government a party to proceedings in that Division for the purpose of their adjudicating all the Government's claims, both state and federal, pursuant to the McCarran Amendment. That law provided for consent to join the United States in any suit (1) for the adjudication of water rights, or (2) the administration of such rights, where it appeared that the United States owned or was acquiring such rights by appropriation under state law or otherwise. The district court, on abstention grounds, granted a motion to dismiss the Government's suit. The court of appeals reversed, holding that jurisdiction for that suit existed under 28 U.S.C.S. § 1345, and that abstention was inappropriate.
Did the district court have jurisdiction to grant a motion to dismiss the Government's suit?
The Supreme Court of the United States held the Amendment did not diminish the district court's jurisdiction under 28 U.S.C.S. § 1345, but that dismissal was proper in view of the concurrent state court proceedings. In so holding, the Court found that, under the Amendment, the state court had jurisdiction over Indian water rights and that, although the abstention doctrine did not apply, a number of factors counseled against concurrent federal proceedings. Those factors included the Amendment's clear federal policy of avoiding piecemeal adjudication of water rights in a river system, the adjudication system established by the state's Water Rights Determination and Administration Act and the extensive involvement of state water rights.
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