City of Fishers, Indiana v. DIRECTV

Dist. Ct. did not err in dismissing instant action and remanding matter back to state court under comity abstention doctrine, where plaintiffs-Indiana cities sought declaration in state court that defendants-video-streaming platforms owed them past and future franchise fees under Indiana statute, and where instant action had been removed to federal court. Dist. Ct. could properly base instant dismissal on comity abstention doctrine, where instant action concerned challenge to state taxation of commercial activity, and where instant attempt by plaintiffs to collect revenue is core function of state government. Fact that plaintiffs were local governmental units did not require different result. Also, under Levin, 560 U.S. 413, instant action qualified for application of comity abstention doctrine since: (1) defendants sought federal-court review of commercial matters over which state enjoyed wide regulatory latitude; (2) defendants were seeking federal court aid in endeavor to improve their competitive position vis a vis traditional cable carriers who pay franchise fee; and (3) state courts are better equipped to resolve instant dispute.