Quackenbush v. Allstate Ins. Co., 517 U.S. 706, 19 (1996)

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Opinion of the Court

orders in a single set of state courts, "[t]o prevent the confusion of multiple review," id., at 326, and to permit an experienced cadre of state judges to obtain "specialized knowledge" in the field, id., at 327. Though Texas had thus demonstrated its interest in maintaining uniform review of the Commission's orders, the federal courts had, in the years preceding Burford, become increasingly involved in reviewing the reasonableness of the Commission's orders, both under a constitutional standard imposed under the Due Process Clause, see, e. g., Railroad Comm'n of Tex. v. Rowan & Nichols Oil Co., 310 U. S. 573, 577 (1940), and under state law, which established a similar standard, see Burford, 319 U. S., at 317, 326.

Viewing the case as "a simple proceeding in equity to

enjoin the enforcement of the Commissioner's order," id., at 317, we framed the question presented in terms of the power of a federal court of equity to abstain from exercising its jurisdiction:

"Although a federal equity court does have jurisdiction of a particular proceeding, it may, in its sound discretion, whether its jurisdiction is invoked on the ground of diversity of citizenship or otherwise, 'refuse to enforce or protect legal rights, the exercise of which may be prejudicial to the public interest,' for it 'is in the public interest that federal courts of equity should exercise their discretionary power with proper regard for the rightful independence of state governments in carrying out their domestic policy.' While many other questions are argued, we find it necessary to decide only one: Assuming that the federal district court had jurisdiction, should it, as a matter of sound equitable discretion, have declined to exercise that jurisdiction here?" Id., at 317- 318 (footnote omitted) (quoting United States ex rel. Greathouse v. Dern, 289 U. S. 352, 360 (1933), and Pennsylvania v. Williams, 294 U. S., at 185).

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