Case Citator › Colorado River Water Conservation District v. United States

Colorado River Water Conservation District v. United States

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
424 U.S. 800
Decided
Confirmed treatments
3
Flagged citations read
91 of 91
Citing cases (total)
6,490
Treatment dates
1994–2023
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Colorado River Water Conservation District v. United States is limited: all 91 flagged citations have been read, with the 3 confirmed treatments listed below. American Cold Storage, Inc. v. NBD Bank declined to extend Colorado River's exceptional-circumstances test to declaratory-judgment actions, and the Supreme Court later resolved the split in Wilton v. Seven Falls Co. by holding that Brillhart's discretionary standard governs that context.
More on how this was screened

Pixis Drones, LLC v. Lumenier LLC held that Colorado River abstention cannot override a mandatory forum-selection clause. The other opinions applied or clarified Colorado River, reported treatment of other authorities, or used nearby adverse terms for unrelated arguments and dispositions.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

6,490 later cases cite Colorado River Water Conservation District v. United States; 91 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Colorado River Water Conservation District v. United States?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Supreme Court held that Brillhart's discretionary standard, rather than Colorado River's exceptional-circumstances test, governs a stay of a declaratory-judgment action in favor of parallel state proceedings.

    Wilton v. Seven Falls Co. · Supreme Court of the United States · filed

    This case asks whether the discretionary standard set forth in Brillhart v. Excess Ins. Co. of America, 316 U. S. 491 (1942), or the “exceptional circumstances” test developed in Colorado River Water Conservation Dist. v. United States, 424 U. S. 800 (1976), and Moses H. Cone Memorial Hospital v. Mercury Constr. Corp., 460 U. S. 1 (1983), governs a district court’s decision to stay a declaratory judgment action during the pendency of parallel state court proceedings, and under what standard of review a court of appeals should evaluate the district court’s decision to do so. ... In sum, we conclude that Brillhart v. Excess Ins. Co. of America, 316 U. S. 491 (1942), governs this declaratory judgment action and that district courts’ decisions about the propriety of hearing declaratory judgment actions, which are necessarily bound up with their decisions about the propriety of granting declaratory relief, should be reviewed for abuse of discretion.
    Read the full opinion on CourtListener →

  • The district court declined to extend Colorado River's exceptional-circumstances test to a declaratory-judgment action and instead applied Brillhart's broader discretionary framework.

    American Cold Storage, Inc. v. NBD Bank · S.D. Ind. · filed

    The Seventh Circuit has yet to answer definitively whether Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 96 S.Ct. 1236, 47 L.Ed.2d 483 (1976) supersedes the analysis of Brillhart. The circuit courts, which have considered the issue are split. See Rivera-Puig v. Garcia-Rosario, 983 F.2d 311, 320 (1st Cir.1992) (holding that a federal court’s duty to exercise jurisdiction is relaxed in the declaratory judgment context); Washington Street Corp. v. Lusardi, 976 F.2d 587, 588 (9th Cir.1992) (in declaratory relief cases, Brillhart controls); Insurance Co. of the State of Pa. v. Syntex Corp., 964 F.2d 829, 832-34 (8th Cir.1992) (Colorado River applies to declaratory relief actions filed in federal court and based on diversity jurisdiction). The Court agrees with the First and Ninth Circuit and finds that Brillhart is not overruled by the Colorado River abstention doctrine.
    Read the full opinion on CourtListener →

  • The district court held that Colorado River abstention cannot override a mandatory forum-selection clause.

    Pixis Drones, LLC v. Lumenier LLC · D. Del. · filed

    The Colorado River abstention doctrine cannot be used to abrogate a mandatory forum selection clause. See RGC Int'l Invs., LDC v. ARI Network Servs., Inc., 2003 WL 21843637, at *2 (D. Del. July 31, 2003); FaZe Clan Inc. v. Tenney, 407 F. Supp. 3d 440, 444 (S.D.N.Y. 2019) ("[I]t cannot be the case that Colorado River allows parties to avoid a mandatory forum selection clause in a contract simply by beating their adversary to the courthouse by a period of several weeks.").
    Read the full opinion on CourtListener →

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