” O'Dell v. Doychak, No. 6:06-cv-677-Orl-19KRS, 2006 WL 4509634, at *6 (M.D. Fla. Oct. 20, 2006) (citing Ambrosia Coal, 368 F.3d at 1330).
Ambrosia Coal, 368 F.3d at 1333. It's true (of course) that a federal court need not abstain solely because of repetition or interrelatedness, but a “significant potential that a decision in the state action will moot the issue pending before the [federal] Court” tips the scales in favor of abstention. O'Dell v. Doychak, 2006 WL 4509634, at *7 (M.D. Fla. Oct. 20, 2006) (Fawsett, J.) (finding that abstention was appropriate where the state court's ruling would assist the court in “render[ing] a more accurate decision”). Here, both the state and federal actions involve “the same facts,” mostly the same “parties,” and the very same “set of issues.”
When the federal and state courts are in the same geographical area, courts routinely consider this factor to be neutral. See, e.g., O'Dell v. Doychak, No. 6:06-cv-677-Orl-19KRS, 2006 WL 4509634, at *7 (M.D. Fla. Oct. 20, 2006); Bosdorf v. Beach, 79 F. Supp. 2d 1337, 1344 (S.D. Fla. 1999). Both the state court and this Court are in Orlando, Florida.
The state and federal cases need not share identical parties and issues to be considered parallel for purposes of Colorado River abstention. Ambrosia Coal, 368 F.3d at 1329-30; see also Sini, 990 F. Supp. 2d at 1376; O'Dell v. Doychak, 2006 WL 4509634, at *6 (M.D. Fla. Oct. 20, 2006) ("Parallel proceedings do not have to involve identical parties, issues and requests for relief."); Hendricks v. Mortgage Elec. Registration Sys., Inc., 2013 WL 1279035, at *2 (M.D. Fla. Mar. 28, 2013)
Sini v. Citibank, N.A., 990 F. Supp. 2d 1370, 1376 (S.D. Fla. 2014)(quoting Jackson-Platts, 727 F.3d at 1140). However, the state and federal cases need not share identical parties and issues to be considered parallel for purposes of Colorado River abstention. Ambrosia Coal, 368 F.3d at 1329-30; O'Dell v. Doychak, No. 6:06-cv-677-Orl-19KRS, 2006 WL 4509634, at *6 (M.D. Fla. Oct. 20, 2006)("Parallel proceedings do not have to involve identical parties, issues and requests for relief."). Assuming satisfaction of that threshold issue, the Eleventh Circuit
When the federal and state courts are located in the same geographical area, courts routinely deem this factor to be neutral. E.g., O'Dell v. Doychak, No. 6:06-cv-677-Orl-19KRS, 2006 WL 4509634, at *7 (M.D. Fla. Oct. 20, 2006); Bosdorf v. Beach, 79 F. Supp. 2d 1337, 1344 (S.D. Fla. 1999). Such is the case here, where both the federal and state courts are located in Orlando.