Quackenbush v. Allstate Ins. Co., 517 U.S. 706, 14 (1996)

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Cite as: 517 U. S. 706 (1996)

Opinion of the Court

determining whether and when to entertain an action under the Declaratory Judgment Act, even when the suit otherwise satisfies subject matter jurisdictional prerequisites").

Nevertheless, we have not previously addressed whether the principles underlying our abstention cases would support the remand or dismissal of a common-law action for damages. Cf. Deakins v. Monaghan, 484 U. S. 193, 202, and n. 6 (1988) (reserving the question whether Younger requires abstention in an action for damages); Ankenbrandt v. Richards, 504 U. S. 689 (1992) (discussing, without applying, Burford abstention in damages action). To be sure, we held in Fair Assessment in Real Estate Assn., Inc. v. McNary, supra, that a federal court should not entertain a 42 U. S. C. 1983 suit for damages based on the enforcement of a state tax scheme, see 454 U. S., at 115, but we have subsequently indicated that Fair Assessment was a case about the scope of the 1983 cause of action, see National Private Truck Council, Inc. v. Oklahoma Tax Comm'n, 515 U. S. 582, 589-590 (1995), not the abstention doctrines. To the extent Fair Assessment does apply abstention principles, its holding is very limited. The damages action in that case was based on the unconstitutional application of a state tax law, and the award of damages turned first on a declaration that the state tax was in fact unconstitutional. We therefore drew an analogy to Huffman and other cases in which we had approved the application of abstention principles in declaratory judgment actions, and held that the federal court should decline to hear the action because "[t]he recovery of damages under the Civil Rights Act first requires a 'declaration' or determination of the unconstitutionality of a state tax scheme that would halt its operation." Fair Assessment, supra, at 115.

Otherwise, we have applied abstention principles to actions "at law" only to permit a federal court to enter a stay order that postpones adjudication of the dispute, not to dismiss the federal suit altogether. See, e. g., Thibodaux, supra, at 28-30 (approving stay order); Fornaris v. Ridge


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