 Chase Brexton Health Services, Incorporated v. the State of Maryland, Department of Health and Mental Hygiene

PUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
 CHASE BREXTON HEALTH SERVICES,
INCORPORATED; CHOPTANK
COMMUNITY HEALTH SYSTEM,
INCORPORATED; COMMUNITY CLINIC,
INCORPORATED; PARK WEST HEALTH
SYSTEM, INCORPORATED; PEOPLE’S
COMMUNITY HEALTH CENTER,
INCORPORATED; THREE LOWER
COUNTIES COMMUNITY HEALTH
SERVICES, INCORPORATED; TOTAL
HEALTH CARE, INCORPORATED,
Plaintiffs-Appellants, No. 04-1710 
v.
THE STATE OF MARYLAND,
DEPARTMENT OF HEALTH AND MENTAL
HYGIENE,
Defendant-Appellee,
and
NELSON SABATINI, Secretary, State of
Maryland Department of Health and
Mental Hygiene,
Defendant. 
Appeal from the United States District Court
for the District of Maryland, at Baltimore.
Marvin J. Garbis, Senior District Judge.
(CA-03-1548-1-MJG)
Argued: March 17, 2005
Decided: June 9, 2005

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Before WILKINS, Chief Judge, NIEMEYER, Circuit Judge,
and Samuel G. WILSON, United States District Judge
for the Western District of Virginia, sitting by designation.
Vacated and remanded by published opinion. Judge Niemeyer wrote
the opinion, in which Chief Judge Wilkins and Judge Wilson joined.
COUNSEL
ARGUED: James Leo Feldesman, FELDESMAN TUCKER LEIFER
FIDELL, L.L.P., Washington, D.C., for Appellants. Joel Lewis Tor-
nari, OFFICE OF THE ATTORNEY GENERAL OF MARYLAND,
Department of Health & Mental Hygiene, Baltimore, Maryland, for
Appellee. ON BRIEF: Kathy S. Ghiladi, FELDESMAN TUCKER
LEIFER FIDELL, L.L.P., Washington, D.C., for Appellants. J.
Joseph Curran, Jr., Attorney General of Maryland, Elizabeth M. Kam-
een, Assistant Attorney General, Baltimore, Maryland, for Appellee.
OPINION
NIEMEYER, Circuit Judge:
Seven healthcare providers commenced this action under 42 U.S.C.
§ 1983 against the Secretary of the Maryland Department of Health
and Mental Hygiene, challenging Maryland’s method for reimbursing
plaintiffs under Maryland’s Medicaid plan on the basis that the
method violated the federal Medicaid law. They seek a declaratory
judgment and injunctive relief.
Invoking the abstention doctrine in Colorado River Conservation
District v. United States, 424 U.S. 800 (1976), the district court stayed
this action in favor of related and pending Maryland administrative
proceedings involving two of the healthcare providers and other
related Maryland administrative proceedings commenced after this
action was commenced.
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Because we conclude that this action does not meet the criteria for
Colorado River abstention, we vacate the district court’s stay order
and remand for further proceedings.
I
Chase Brexton Health Services, Inc.; Choptank Community Health
System, Inc.; Community Clinic, Inc.; Park West Health System, Inc.;
People’s Community Health Center, Inc.; Three Lower Counties
Community Health Services, Inc.; and Total Health Care, Inc. are
healthcare providers that have qualified under the Medicaid program
to provide healthcare services to low-income individuals in Maryland
in exchange for reimbursement from Medicaid funds. The Medicaid
program is a cooperative federal-state program through which the
United States provides financial assistance to participating States to
enable them to pay for healthcare services rendered to those otherwise
unable to afford healthcare. States electing to participate in the pro-
gram must comply with requirements imposed by federal law and
have an approved "State Medicaid plan," under which qualified
healthcare providers are reimbursed for the services they render. See
42 U.S.C. § 1396a(a).
The methods for reimbursement provided by federal law have
changed over the years. Between 1989 and 1997, the federal Medicaid
law required States to reimburse qualified healthcare providers for
"100 percent of costs which are reasonable and related to the cost of
furnishing such services or based on such other tests of reasonable-
ness as the Secretary prescribes in regulations." Pub. L. No. 101-239,
§ 6404(a), (c), 103 Stat. 2106, 2264 (1989) (originally codified as 42
U.S.C. § 1396a(a)(13)(E)). From 1997 until 2000, the federal Medic-
aid law required States to reimburse qualified healthcare providers for
"100 percent (or 95 percent for services furnished during fiscal year
2000 . . .) of costs which are reasonable and related to the cost of fur-
nishing such services or based on such other tests of reasonableness
as the Secretary prescribes in regulations." Pub. L. No. 105-33,
§ 4712(a), 111 Stat. 251, 508 (1997) (originally codified as 42 U.S.C.
§ 1396a(a)(13)(C)). Finally, at the end of 2000, Congress amended
federal law to require States to implement prospective payment sys-
tems for funding qualified healthcare providers. The prospective pay-
ments prescribed, however, are based on a "reasonable cost"
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reimbursement requirement similar to the requirements previously
applied. The reasonable cost requirement instructs States to start with
a base amount equal to "an amount (calculated on a per visit basis)
that is equal to 100 percent of the average of the costs of the center
or clinic of furnishing such services during fiscal years 1999 and 2000
which are reasonable and related to the cost of furnishing such ser-
vices, or based on such other tests of reasonableness as the Secretary
prescribes in regulations." Pub. L. No. 106-554, § 1(a)(6), 114 Stat.
2763, 2763, 2763A-572-73 (2000) (currently codified as 42 U.S.C.
§ 1396a(bb)(2)). For every year after 2001, the reimbursement level
increases from that base amount by a predetermined percentage. 42
U.S.C. § 1396a(bb)(3).
In June 2000, People’s Community Health Center, Inc. and Com-
munity Clinics, Inc., two of the appellants in this case, filed adminis-
trative appeals with the Maryland Department of Health and Mental
Hygiene ("Maryland Department of Health"), disputing Maryland’s
determination of their reimbursement amounts for their fiscal years
1996-1998. These two healthcare providers contended that an admin-
istrative cap and a rate ceiling imposed by Maryland violated the fed-
eral law that required the reimbursement of all of the healthcare
providers’ reasonable costs. A Maryland administrative law judge
conducted a hearing on the two appeals and, on March 24, 2003,
issued a proposed order concluding that "Maryland’s regulation pro-
viding for an administrative cap, as applied[,] conflicted with Federal
law and [was] arbitrary and capricious" but that the evidence was
insufficient to conclude that the rate ceiling was illegal. The Maryland
Department of Health filed exceptions to the proposed order in April
2003, and, the Secretary of the Maryland Department of Health has,
as counsel for Maryland have informally advised the court, issued a
final decision reversing the administrative law judge. The Secretary’s
decision is now before the Maryland Board of Review, which, accord-
ing to counsel for Maryland, is the "last stop" in the Maryland admin-
istrative process before appellants are given access to Maryland
courts.
While the appeals of the two healthcare providers were pending
before the Maryland Department of Health, the seven healthcare pro-
viders named above commenced this action on May 27, 2003, against
the Maryland Department of Health and Nelson J. Sabatini in his offi-
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cial capacity as Secretary of the Maryland Department of Health. The
seven healthcare providers requested: (1) an injunction requiring the
Maryland Department of Health to implement the "prospective pay-
ment system" required by Congress in 2000; (2) a declaration that the
Maryland Department of Health’s use of the administrative cap and
rate ceiling before enactment of the prospective payment system at
the end of 2000 violated the reasonable cost requirements of federal
law; (3) an injunction prohibiting the Maryland Department of Health
from using the administrative cap and rate ceiling in reaching a final
settlement for the years 1999 and 2000; and (4) an injunction prohib-
iting the Maryland Department of Health from using the administra-
tive cap and rate ceiling in calculating the per-visit rates for 1999 and
2000 that are to be used in setting the prospective payment rates for
the years after 2000.
After this action was commenced and while it was pending, the
Maryland Department of Health determined the prospective payment
rates for each qualified healthcare provider, and the seven healthcare
providers in this case appealed those determinations administratively,
contending that those rates also violated federal law because they
incorporated an administrative cap and rate ceiling in the calculations
of the base 1999 and 2000 rates. Counsel for Maryland have infor-
mally advised this court that an administrative law judge has held a
hearing on those appeals and issued a proposed order upholding the
prospective rate determinations made by the Maryland Department of
Health. That order remains pending within the state administrative
process.
In this action, upon Maryland’s motion to dismiss or for summary
judgment, the district court dismissed the healthcare providers’ claims
against the Maryland Department of Health on sovereign immunity
grounds, leaving the providers’ claims pending against the Secretary
of the Maryland Department of Health. The district court also dis-
missed the healthcare providers’ first claim — that the Maryland
Department of Health failed to implement a prospective payment sys-
tem — because, as of the time the court considered the motion, the
Maryland Department of Health had established such a system. With
respect to the healthcare providers’ second claim — that the adminis-
trative cap and rate ceiling applied by the Maryland Department of
Health violated federal law — the district court stayed the proceed-
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ings pending the outcome of state administrative proceedings, relying
on Colorado River Water Conservation District v. United States, 424
U.S. 800 (1976).
The healthcare providers appeal only the district court’s stay order.
II
In applying Colorado River abstention to stay the proceedings in
this case, the district court considered as parallel state proceedings not
only the two administrative appeals filed before the commencement
of this action but also the administrative appeals filed after because
it concluded that the issue to be decided in the administrative appeals
and in this action was the same. The court observed, "[b]ecause of
issue and claim preclusion principles, it may be that only one forum
can decide this question (that is, the forum that decides first)." The
court reasoned that "proceeding to the merits of this claim would
mean that at least one tribunal’s adjudicative resources would be
unnecessarily squandered." The court reasoned in the alternative that
if different issues were being adjudicated in the administrative pro-
ceedings and in this action based on differing constructions of "rea-
sonableness" as used in the various versions of the Medicaid law, the
resulting "‘piecemeal’ uncertainty" would become "precisely" the
kind of problem that Colorado River sought to avoid.
The healthcare providers contend that the district court misapplied
Colorado River and that the factors and policies governing Colorado
River abstention do not "fit the facts in this case." They argue that the
district court overlooked altogether the strong presumption that "the
statutory rights of Medicaid beneficiaries and others who participate
in the program (such as health care providers) are enforceable in the
federal courts," citing to 42 U.S.C. § 1320a-2, and that Colorado
River abstention is a narrow and limited exception to a federal court’s
obligation to exercise its jurisdiction.
We begin by recognizing the general rule that our dual system of
federal and state governments allows parallel actions to proceed to
judgment until one becomes preclusive of the other. "Despite what
may appear to result in a duplication of judicial resources, ‘[t]he rule
is well recognized that the pendency of an action in the state [system]
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is no bar to proceedings concerning the same matter in the Federal
court having jurisdiction.’" McLaughlin v. United Va. Bank, 955 F.2d
930, 934 (4th Cir. 1992) (quoting McClellan v. Carland, 217 U.S.
268, 282 (1910)).
In addition, we recognize the general rule that federal courts are
bound by a "virtually unflagging obligation . . . to exercise the juris-
diction given them." Colorado River, 424 U.S. at 817. Federal courts
"have no more right to decline the exercise of jurisdiction which is
given, than to usurp that which is not." Cohens v. Virginia, 19 U.S.
(6 Wheat.) 264, 404 (1821). But this duty is not absolute. In certain
limited instances, "federal courts may decline to exercise their juris-
diction, in otherwise ‘exceptional circumstances,’ where denying a
federal forum would clearly serve an important countervailing inter-
est." Quackenbush v. Allstate Ins. Co., 517 U.S. 706, 716 (1996)
(quoting Colorado River, 424 U.S. at 813). These "exceptional cir-
cumstances" inevitably relate to a policy of avoiding unnecessary
constitutional decisions and of accommodating federal-state relations.1
Quite apart from the important policies underlying traditional
grounds for abstention, Colorado River, solely as a matter of judicial
administration, permits dismissal of a duplicative federal action when
"[w]ise judicial administration, giving regard to conservation of judi-
cial resources and comprehensive disposition of litigation" clearly
1Thus, for example, the Supreme Court has held that federal courts
have the power to refrain from hearing: (1) cases that would interfere
with a pending state criminal proceeding, see Younger v. Harris, 401
U.S. 37 (1971), or with certain types of state civil proceedings, see Huff-
man v. Pursue, Ltd., 420 U.S. 592 (1975); (2) cases in which the resolu-
tion of a federal constitutional question might be mooted if the state
courts were given the opportunity to interpret ambiguous state law, see
R.R. Comm’n of Texas v. Pullman Co., 312 U.S. 496 (1941); (3) cases
raising issues "intimately involved with [the States’] sovereign preroga-
tive," the proper adjudication of which might be impaired by unsettled
questions of state law, see La. Power & Light Co. v. City of Thibodaux,
360 U.S. 25, 28 (1959); (4) cases whose resolution might interfere with
state schemes for the collection of taxes, see Great Lakes Dredge and
Dock Co. v. Huffman, 319 U.S. 293 (1943); and (5) cases involving com-
plex state administrative procedures, see Burford v. Sun Oil Co., 319
U.S. 315 (1943).
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favors abstention. 424 U.S. at 817 (quoting Kerotest Mfg. Co. v. C-O-
Two Fire Equip. Co., 342 U.S. 180, 183 (1952) (internal quotation
marks omitted); see also Moses H. Cone Mem’l Hosp. v. Mercury
Constr. Corp., 460 U.S. 1, 15 (1983); McLaughlin, 955 F.2d at 935.
Because Colorado River abstention does not rest on the weightier
concerns of proper constitutional adjudication and federal-state rela-
tions, the Supreme Court has admonished that it be applied parsimo-
niously. As the Court explained:
Given [the virtually unflagging obligation of the federal
courts to exercise the jurisdiction given them], and the
absence of weightier considerations of constitutional adjudi-
cation and state-federal relations, the circumstances permit-
ting the dismissal of a federal suit due to the presence of a
concurrent state proceeding for reasons of wise judicial
administration are considerably more limited than the cir-
cumstances appropriate for abstention. The former circum-
stances, though exceptional, do nevertheless exist.
424 U.S. at 818 (emphasis added).
At bottom, in assessing whether Colorado River abstention is
appropriate, a district court must remain mindful that this form of
abstention "is an extraordinary and narrow exception to the duty of
a District Court to adjudicate a controversy properly before it" and
that "[a]bdication of the obligation to decide cases can be justified
under [abstention] only in the exceptional circumstances where the
order to the parties to repair to the State court would clearly serve an
important countervailing interest." Colorado River, 424 U.S. at 813
(quoting Allegheny County v. Frank Mashuda Co., 360 U.S. 185, 188-
89 (1959)) (internal quotation marks omitted). As such, our task "is
not to find some substantial reason for the exercise of jurisdiction by
the district court; rather, our task is to ascertain whether there exist
‘exceptional’ circumstances, the ‘clearest of justifications,’ . . . to jus-
tify the surrender of that jurisdiction." Moses H. Cone, 460 U.S. at
25-26.
The threshold question in deciding whether Colorado River absten-
tion is appropriate is whether there are parallel federal and state suits.2
2For this purpose, administrative proceedings, when adjudicative in
nature, are considered state suits. See Martin Marietta Corp. v. Md.
Comm’n on Human Relations, 38 F.3d 1392, 1396 (4th Cir. 1994).
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See New Beckley Mining Corp. v. Int’l Union, UMWA, 946 F.2d
1072, 1073 (4th Cir. 1991). If parallel suits exist, then a district court
must carefully balance several factors, "with the balance heavily
weighted in favor of the exercise of jurisdiction." Moses H. Cone, 460
U.S. at 16. Although the prescribed analysis is not a "hard-and-fast"
one in which application of a "checklist" dictates the outcome, six
factors have been identified to guide the analysis: (1) whether the sub-
ject matter of the litigation involves property where the first court
may assume in rem jurisdiction to the exclusion of others; (2) whether
the federal forum is an inconvenient one; (3) the desirability of avoid-
ing piecemeal litigation; (4) the relevant order in which the courts
obtained jurisdiction and the progress achieved in each action; (5)
whether state law or federal law provides the rule of decision on the
merits; and (6) the adequacy of the state proceeding to protect the par-
ties’ rights. Id. at 15-16, 19-27; Colorado River, 424 U.S. at 818-19;
McLaughlin, 955 F.2d at 934-35. In the end, however, abstention
should be the exception, not the rule, and it may be considered only
when "the parallel state-court litigation will be an adequate vehicle
for the complete and prompt resolution of the issues between the par-
ties." Moses H. Cone, 460 U.S. at 28.
Because any such decision to abstain falls within a district court’s
discretion, we review the decision for abuse of discretion. Al-Abood
v. El-Shamari, 217 F.3d 225, 232 (4th Cir. 2000).
Addressing first whether the present action is parallel to the state
proceedings, we believe that the district court acted at too general a
level and tended, when in doubt, to favor abstention, an approach that
violated the principles noted above.
The state proceedings pending when this action was commenced
involved two state administrative appeals by two of the healthcare
providers in this case, challenging the amount of the reimbursement
determined by the Maryland Department of Health for the fiscal years
1996-1998. This action, in contrast, involves the claims of seven
healthcare providers — including the two that were parties to the
administrative appeals — challenging reimbursement methods not
only for 1996-1998, but also for the other years before January 1,
2001, as well as for the years after January 1, 2001, when the Mary-
land Department of Health switched to a prospective payment system.
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Discounting the differences between the administrative appeals and
this case, the district court noted that the parties and issues in Colo-
rado River itself were not identical to the "parallel" state-court pro-
ceeding and, as such, concluded for this case that "the commonalities
between adjudications sufficiently outweigh[ed] the differences."
While the district court correctly noted that the parties in Colorado
River were not identical to the parties in the "parallel" state action, the
district court failed to recognize that in Colorado River at least the
federal plaintiff was a party to the state action. 424 U.S. at 805-06.
In this case, five of the federal plaintiffs were not involved in the
pending administrative appeals. Accordingly, to abstain in favor of
those state administrative appeals would deprive five healthcare pro-
viders of the opportunity to litigate their claims. Moreover, we have
strictly construed the requirement of parallel federal and state suits,
requiring that the parties involved be almost identical. "Suits are par-
allel if substantially the same parties litigate substantially the same
issues in different forums." New Beckley, 946 F.2d at 1073.
In addition to the lack of similarity of parties, the scope of the
plaintiffs’ claims are not parallel. The two healthcare providers that
are parties to the administrative appeals challenged their reimburse-
ment levels only for the fiscal years 1996-1998. While their federal-
court challenges based on later years might involve similar issues,
these challenges will also entail additional and distinct issues because
of the intervening change in the Medicaid law. Specifically, the first
administrative challenge will determine only whether the administra-
tive cap and rate ceilings violated the requirement that the Maryland
Department of Health reimburse "100 percent . . . of costs which are
reasonable," 42 U.S.C. § 1396a(a)(13)(C) (1998), whereas the federal
challenge will also have to determine whether the administrative cap
and rate ceiling violated the requirement that the Maryland Depart-
ment of Health base its prospective payment system on "an amount
. . . that is equal to 100 percent of the average of the costs of the cen-
ter . . . during fiscal years 1999 and 2000," 42 U.S.C. § 1396a(bb)(2)
(2005). In addition, the administrative law judge’s method of deter-
mining whether the administrative cap and rate ceiling violated fed-
eral law demonstrates that factual differences among the challenged
years could well have a significant effect on whether the administra-
tive cap and rate ceiling violated federal law. Specifically, the admin-
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istrative law judge found that the Maryland Department of Health’s
method of calculating reimbursement levels did not facially violate
federal law but that during the challenged years, the cap and ceiling
resulted in less than 100% reimbursement of reasonable costs.
In New Beckley, we held that the state and federal actions, although
"virtually identical," were not parallel because the remedies sought
and the issues raised were not the same. 946 F.2d at 1074. In so hold-
ing, we concluded that "‘[t]he Colorado River doctrine does not give
federal courts carte blanche to decline to hear cases within their juris-
diction merely because issues or factual disputes in those cases may
be addressed in past or pending proceedings before state tribunals.’"
Id. (quoting United States v. SCM Corp., 615 F. Supp. 411, 417 (D.
Md. 1985)). Consistent with this view, we conclude that the district
court incorrectly determined that the commonality of a legal issue
outweighed the differences between the pending state administrative
proceedings and this action.
With respect to the administrative appeals filed by the healthcare
providers after this action was commenced, the district court opted to
abstain in favor of those proceedings because (1) there was a likeli-
hood that the federal and state proceedings would result in "disjointed
or unreconcilable results," and (2) significant progress had already
been made in the state administrative proceedings. Even without con-
sidering the important countervailing factors that (1) the administra-
tive proceedings were begun after the commencement of this action
and (2) this action was filed to resolve federal, not state, law, we are
not persuaded that the two factors identified by the district court are
sufficiently weighty to overcome the strong presumption in favor of
its retaining federal jurisdiction. This becomes yet more clear when
we apply all of the factors given in Colorado River and Moses H.
Cone for the analysis.
Consideration of the first and second factors — whether the subject
matter of the state litigation involves a res or whether the federal
forum is an inconvenient one — does not provide any support for
abstention.
With respect to the third factor — the desirability of avoiding
piecemeal litigation — the district court found that the two adjudica-
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tions might end with "disjointed or unreconcilable results." But this
is not the threat of piecemeal litigation with which Colorado River
was concerned; it is a prospect inherent in all concurrent litigation.
And the Supreme Court in Colorado River has instructed federal
courts that they are normally to accept jurisdiction even in the face
of concurrent state litigation. 424 U.S. at 817. The "mere potential for
conflict in the results of adjudications, does not, without more, war-
rant staying exercise of federal jurisdiction." Id. at 816. The threat of
piecemeal litigation in the sense that two cases proceed simulta-
neously thus is not sufficient to support a decision to abstain under
Colorado River.
The fourth factor — the order in which jurisdiction was obtained
by the courts — counsels against abstention since the healthcare pro-
viders filed their federal claim before they filed their administrative
appeals. Moreover, at the time of the district court’s order, the admin-
istrative appeals had not even proceeded to a hearing. Thus, both the
relative progress of the proceedings and the order of filings weigh
decidedly against abstention.
The fifth factor — whether the source of law is federal or state —
strongly counsels in favor of the district court’s exercising jurisdic-
tion. The healthcare providers in this case contend that the Maryland
Department of Health’s reimbursement methods violated federal
Medicaid law, and that law expressly provides federal jurisdiction to
resolve disputes under the law. See 42 U.S.C. § 1320a-2. Indeed, the
present proceedings raise no substantial issue of state law.
The sixth factor — whether the state proceeding will adequately
protect the rights of the parties seeking to invoke federal jurisdiction
— also weighs against abstention. The district court was well aware
of the slow pace of the state administrative proceedings and, based on
the record before it, the district court had no reason to assume that the
administrative proceedings were an adequate vehicle for the "prompt
resolution" of the claims. See Moses H. Cone, 460 U.S. at 28. The
healthcare providers also raise a legitimate question about whether a
state administrative agency reviewing a reimbursement claim can pro-
vide the full relief that the healthcare providers are requesting in this
action. Counsel for Maryland were unable to assure us at oral argu-
ment that a state administrative law judge has the power to declare
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that the law under which it operates violates federal law or to issue
injunctions against the Secretary of the Maryland Department of
Health.
In tallying the relevant factors and considering them against the
larger policies underlying Colorado River abstention, we cannot con-
clude that this case presents the "exceptional circumstances" that jus-
tify a federal court’s surrendering its jurisdiction in favor of state
administrative proceedings.
III
In support of the district court’s stay order, Maryland argues addi-
tionally that the district court possessed even broader discretion under
the Declaratory Judgment Act, 28 U.S.C. § 2201, to stay an action
and that its order staying this action can be justified as a proper exer-
cise of that discretion. See Wilton v. Seven Falls Co., 515 U.S. 277,
286 (1995).
It is true that the granting of declaratory relief is entrusted to the
discretion of the district court. Section 2201 explicitly provides that
"any court of the United States, upon the filing of an appropriate
pleading, may declare the rights and other legal relations of any inter-
ested party seeking such declaration." (Emphasis added). But when a
plaintiff seeks relief in addition to a declaratory judgment, such as
damages or injunctive relief, both of which a court must address, then
the entire benefit derived from exercising discretion not to grant
declaratory relief is frustrated, and a stay would not save any judicial
resources. The claims in this case for which declaratory relief is
requested and those for which injunctive relief is requested are so
closely intertwined that judicial economy counsels against dismissing
the claims for declaratory judgment relief while adjudicating the
claims for injunctive relief. Accordingly, we reject Maryland’s addi-
tional argument.
IV
For all of the reasons given, we conclude that the district court
abused its discretion in staying the proceedings in this case under the
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Colorado River abstention doctrine, pending the outcome of state
administrative proceedings. Accordingly, we vacate the district
court’s abstention order and remand for further proceedings.
VACATED AND REMANDED
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