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CenturyTel of Chatham, LLC v. Sprint Communications Co.

Citations: 185 F. Supp. 3d 932; 2016 U.S. Dist. LEXIS 59777; 2016 WL 2347926Docket: CIVIL ACTION NO. 09-1951

Court: District Court, W.D. Louisiana; May 4, 2016; Federal District Court

Narrative Opinion Summary

This case involves a dispute between telecommunications companies CenturyLink and Sprint over unpaid access charges related to the termination of VoIP traffic. CenturyLink, the plaintiff, filed a lawsuit to recover approximately $8.8 million in access charges, alleging Sprint's failure to pay the rates specified in federal and state tariffs. Sprint counterclaimed, seeking a declaratory judgment that it was not required to pay these rates, arguing that VoIP calls should be classified as information services, thus exempt from traditional telecommunications tariffs. The case was heard in a bench trial, with the court ultimately ruling in favor of CenturyLink. The court determined that Sprint was obligated to pay the access charges as per the filed tariffs, rejecting Sprint's preemption arguments and self-help measures of withholding payments. The decision reaffirmed the applicability of the filed rate doctrine and dismissed Sprint's claims that VoIP calls were not subject to access charges. CenturyLink was awarded the disputed amount, along with attorneys' fees and interest, with the court emphasizing that federal law under 47 U.S.C. 201(b) prohibits unjust and unreasonable practices in telecommunications, which Sprint's actions constituted.

Legal Issues Addressed

Filed Rate Doctrine

Application: CenturyLink argues that it is entitled to rates established in its filed tariffs, and the court cannot alter these rates under the filed rate doctrine.

Reasoning: Moreover, CenturyLink asserts that it is entitled to the rates established in the filed tariffs, as the Court cannot alter these rates under the filed rate doctrine.

Jurisdiction over Telecommunications Disputes

Application: The court has jurisdiction under federal statutes over disputes involving telecommunications services and tariffs.

Reasoning: Subject matter jurisdiction is established under 28 U.S.C. §§ 1331 and 1337 for CenturyLink's claims, which allege violations of federal access tariffs and the Communications Act of 1934.

Preemption by Federal Law

Application: Sprint argues that state regulations on VoIP traffic are preempted by federal law, specifically citing the FCC's authority.

Reasoning: Sprint contends that any state regulation of VoIP-originated calls is preempted by the FCC, asserting liability only at federal rates instead of higher state rates.

Termination of Parental Rights under Civil Code Section 232

Application: The case involves CenturyLink's claims against Sprint for unpaid access charges under federal and state tariffs for VoIP traffic termination, with Sprint contesting the applicability of such tariffs.

Reasoning: CenturyLink claims that Sprint violated Federal and State Access Tariffs by not paying access charges, while Sprint counters with claims asserting the inapplicability of these tariffs to VoIP calls and seeks a refund for overbilling.

Unjust or Unreasonable Practices in Telecommunications

Application: Sprint's withholding of payments was deemed unjust and unreasonable under 47 U.S.C. 201(b), based on its self-help measures.

Reasoning: The court cited precedent affirming that self-help measures, like withholding payment, are improper. Consequently, Sprint's actions were deemed unjust and unreasonable, resulting in judgment against Sprint on Count III.