Black Sea Investment, Ltd., Plaintiff-Counter v. United Heritage Corporation, Defendant-Counter Claimant-Appellee

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a party’s 5 claim for coercive relief cannot be ignored simply because it is “‘ancillary to its request for declaratory relief”
• holding that when duplicative litigation exists, Colorado River prevents “piecemeal litigation, and the concomitant danger of inconsistent rulings with respect to a piece of property.”
• explaining that this factor evaluates “how much progress has 7 Case: 24-20092 Document: 81-1 Page: 8 Date Filed: 10/20/2025 No. 24-20092 been made in the two actions” (citation omitted)
• noting that these factors only rarely can be used to support abstention
• treating the fifth Colorado River abstention factor as “at most neutral” in a case involving only state claims
• weighing the third Colorado River abstention factor against abstention when the defendant had demonstrated only a risk of duplicative litigation—not piecemeal litigation

Source: CourtListener parenthetical corpus (CC0).