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Burford abstention is an extraordinary and narrow exception to a federal court's duty to exercise jurisdiction. In other words, burford abstention means a federal court’s refusal to review a state court’s decision in cases involving the presence of a complex regulatory system which would be disrupted by federal court intervention, and the existence of a state forum with specific competence for centralized review. Usually, burford abstention is limited to equitable actions. Burford abstention is appropriate only where there are difficult questions of state law bearing on policy problems whose importance transcends the result in the case. Burford abstention is designed to address the case where federal review of the issues in a case would be disruptive of state efforts to establish a coherent policy with respect to a matter of substantial state concern.
A keystone of Burford abstention is that a decision in a district court would have a substantial impact on policy formation and implementation, transcending the decision of the case then at bar. Where there is no indication of such a wide ranging effect, abstention, resulting in the plaintiffs' loss of a federal forum, cannot be justified.
In Todd v. DSN Dealer Serv. Network, 861 F. Supp. 1531 (D. Kan. 1994), the court observed that “The Burford abstention doctrine is as follows: 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 a 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.”