Saucier v. Aviva Life and Annuity Co.
This case stemmed from a dispute over annuity payments. Counter Defendants, RSL, appealed the district court's decision to abstain based on the doctrine of Colorado River Water Conservation District v. United States. Under the Colorado River doctrine, a court could abstain from a case that was part of parallel, duplicative litigation under "exceptional circumstances." The court examined the six relevant factors under Colorado River and reversed and remanded for further proceedings. On remand, the district court should determine whether RSL was entitled to compel arbitration under 9 U.S.C. 3. The district court must determine in the first instance whether any issues or claims decided by the state court were entitled to preclusive effect. View "Saucier v. Aviva Life and Annuity Co." on Justia Law