American Journal of Law & Medicine

Third Circuit says abstention proper in litigation against Virgin Islands Board of Medical Examiners.

Third Circuit Says Abstention Proper in Litigation Against Virgin Islands Board of Medical Examiners--Williams v. Virgin Islands Board of Medical Examiners. (1)--The United States Court of Appeals for the Third Circuit affirmed the District Court for the Virgin Islands' decision to abstain from review of disciplinary proceedings involving Dr. Wilbert Williams and the Virgin Islands Board of Medical Examiners ("Board"). According to the district court, because the state proceedings against Williams were ongoing, judicial in nature, and provided Williams with opportunity to bring his constitutional claim, abstention under the Younger v. Harris (2) line of cases was proper. (3) Furthermore, because Williams failed to produce evidence of bias on the part of the Board, the exceptions to Younger did not apply. (4)

The original disciplinary proceedings against Dr. Williams stemmed from his allegedly negligent treatment of patient Lydia Ventura. (5) Williams had treated Ventura for general body aches and weaknesses. (6) Several days after seeing Williams, Ventura died. (7) Upon receipt of a letter describing Williams' treatment of Ventura, the Board initiated disciplinary proceedings against Williams. (8) Following a hearing at which Williams was present, the Board suspended Williams' medical license for one year. (9) Williams immediately commenced an action against the Board in the United States District Court for the Virgin Islands, asserting, among other claims, due process violations. (10) After a hearing, the district court dismissed Williams' claims, citing the Younger v. Harris abstention doctrine. (11) In an unpublished, non-precedential decision, the United States Court of Appeals for the Third Circuit affirmed.

The Younger v. …

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