Kanciper v. Suffolk County SPCA, No. 13-1000 (2d Cir. 2013)
Annotate this CasePlaintiff filed suit against the SPCA and others, seeking damages as a result of a search of her property and her arrest based on allegations of equine abuse. The district court applied claim splitting principles to dismiss plaintiff's 42 U.S.C. 1983 action because she filed a suit for tort damages based on the same facts in state court. Applying the Supreme Court's Colorado River abstention standard, the court concluded, however, that the district court's decision to dismiss the federal claim because of a similar pending state court litigation was erroneous. The court held that the district court erred in dismissing plaintiff's declaratory judgment claim because Brillhart/Wilton abstention could not apply when plaintiff sought damages in addition to declaratory relief. Accordingly, the court vacated and remanded for further proceedings.
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