Exceptionally Navigating Abstention: Northern District of Illinois Applies the Colorado River Doctrine to Stay Arbitration

An insurer and a policyholder entered into an agreement, or didn’t they? Either way, the Northern District of Illinois doesn’t have to decide because “exceptional circumstances” triggered the Colorado River abstention doctrine, allowing the court to stay the case asking it to determine whether the agreement existed. A policyholder and one of its insurers began having disputes about who had to provide coverage for certain claims. As a result of those disputes, the policyholder and the insurer allegedly entered into
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