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Abstention is when the Supreme Court refuses to hear a case it has jurisdiction over or declines to consider a question of state law arising from a case being appealed from a state court.
A number of circumstances exist under which a federal court may decline to hear the merits of a case even though it has jurisdiction over the matter under the United States Constitution. These circumstances have been recognized in a number of decisions which have established the "abstention" doctrine. Abstention is generally recognized: (1) to avoid decision of a federal constitutional question where the case may be disposed of on questions of state law; (2) to avoid needless conflict with a state's administration of its own affairs; (3) to leave to the states the resolution of unsettled questions of state law; and (4) to ease the congestion of the federal court docket. The second type of abstention noted above is known as the Burford abstention doctrine because it takes its name from the leading case of Burford v. Sun Oil Co., 319 U.S. 315 (1943).
In Burford, the Texas legislature developed a regulatory body, known as the Railroad Commission, and endowed it with exclusive regulatory authority over the oil industry. The Texas legislature further granted the authority to review the Railroad Commission's orders to a single set of state courts. The federal court was asked to enjoin the enforcement of an order of the Railroad Commission. The Supreme Court upheld the federal district court's abstention from exercising federal jurisdiction: (1) due to the thorny regulatory issues involved which the Texas legislature had assigned to a specialized regulatory body and court; (2) to avoid the confusion of multiple review; and (3) to avoid contrary adjudication by state and federal courts.(7) As such, the Burford court held that abstention in that case was warranted in order to avoid interference with a state's administration of its own affairs.
Where timely and adequate state-court review is available, a federal court sitting in equity must decline to interfere with the proceedings or orders of state administrative agencies: (1) when there are "difficult questions of state law bearing on policy problems of substantial public import whose importance transcends the result in the case then at bar"; or (2) where the "exercise of federal review of the question in the case and in similar cases would be disruptive of state efforts to establish a coherent policy with respect to a matter of substantial public concern."