Colorado River abstention means a federal court’s decision to refrain while relevant and parallel state court proceedings are existing. It is an extraordinary and narrow exception to the duty of a district court to adjudicate a controversy properly before and can be justified only in the exceptional circumstances where the order to the parties to repair to the State court would clearly serve an important countervailing interest. It grants a federal court the discretion to avoid duplicative litigation in federal court of a matter more properly decided in parallel litigation in state court. However, "the potential for conflict" between a federal action and a parallel state action, standing alone, does not justify staying of the exercise of federal jurisdiction under the Colorado River abstention doctrine.
In general, the Colorado River abstention seeks to minimize the wasted efforts of federal courts and litigants resulting from duplicative litigation of concurrent state and federal cases. Consequently, the doctrine favors abstention when the concurrent state proceeding is more advanced and disfavors abstention when the federal case has proceeded farther.
In Standing Rock Housing Authority v. Tri-County State Bank, Inc., 700 F. Supp. 1544 (D.S.D. 1988), the court held that “Colorado River abstention is to be applied in a pragmatic, flexible manner with a view to the realities of the case at hand. In addition, forms of abstention are not "rigid pigeonholes" but reflect a complex of considerations. Nevertheless, federal courts have derived a multi-factored test from Colorado River and Moses H. Cone to guide application of Colorado River abstention. These factors include: 1) the inconvenience of the federal forum, 2) the desirability of avoiding piecemeal litigation; 3) the order in which jurisdiction was obtained by the courts; 4) the source of governing law; 5) the adequacy of the state court action to protect the rights of the parties; and 6) the relative progress of the state and federal suits.”