- D. Abstention
As outlined in several filings, when the present lawsuit was filed on November 25, 2020, there already were multiple lawsuits pending in Michigan state courts raising the same or similar claims alleged in Plaintiffs’ Amended Complaint. (See, e.g., ECF No. 31 at Pg ID 2193-98 (summarizing five state court lawsuits challenging President Trump’s defeat in Michigan’s November 3, 2020 General Election).) Defendants and the City of Detroit urge the Court to abstain from deciding Plaintiffs’ claims in deference to those proceedings under various abstention doctrines. (Id. at Pg ID 2191-2203; ECF No. 39 at Pg ID 2840-44.) Defendants rely on the abstention doctrine outlined by the Supreme Court in Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976). The City of Detroit relies on the abstention doctrines outlined in Colorado River, as well as those set forth in Railroad Commission of Texas v. Pullman Co., 312 U.S. 496, 500-01 (1941), and Burford v. Sun Oil Co., 319 U.S. 315 (1943). The City of Detroit maintains that abstention is particularly appropriate when resolving election disputes in light of the autonomy provided to state courts to initially settle such disputes.
The abstention doctrine identified in Colorado River permits a federal court to abstain from exercising jurisdiction over a matter in deference to parallel state-court proceedings. Colorado River, 424 U.S. at 813, 817. The exception is found
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