Board of County Commissioners v. Hayden

715 F. Supp. 313, 1989 U.S. Dist. LEXIS 7380, 1989 WL 73425
CourtDistrict Court, D. Kansas
DecidedJune 5, 1989
DocketCiv. A. No. 88-4284-O
StatusPublished

This text of 715 F. Supp. 313 (Board of County Commissioners v. Hayden) is published on Counsel Stack Legal Research, covering District Court, D. Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of County Commissioners v. Hayden, 715 F. Supp. 313, 1989 U.S. Dist. LEXIS 7380, 1989 WL 73425 (D. Kan. 1989).

Opinion

MEMORANDUM AND ORDER

EARL E. O’CONNOR, Chief Judge.

This matter is before the court on the motion of the defendants for the court to abstain from further proceedings in this case. The defendants assert that abstention is proper under the Burford doctrine, the Colorado River doctrine, and/or the [314]*314Pullman doctrine. For the reasons that follow, we grant the motion.

The pertinent facts are as follows: In 1988, the Office of the Kansas Secretary of State conducted a state census which resulted in the reapportionment of voting districts. The instant case against certain state officials was brought by various boards of county commissioners and seventeen (17) individual plaintiffs, alleging that (1) the census is not accurate, (2) the statutes under which the census was conducted, see K.S.A. 11-204 et seq., are unconstitutional on their face and as applied, and (3) the amendment to the state constitution dealing with the census, originally 1988 House Concurrent Resolution No. 5043, is unconstitutional. The plaintiffs contemporaneously filed a similar complaint in state court.

The defendants urge the court to abstain for three alternative reasons: First, there are two comprehensive state schemes to determine the validity of the reapportionment statutes and the census itself; in other words, the court should abstain under the Burford doctrine. See Burford v. Sun Oil Co., 319 U.S. 315, 63 S.Ct. 1098, 87 L.Ed. 1424 (1943). Second, exceptional circumstances merit abstention; in other words, the court should abstain under the Colorado River doctrine. See Colorado River Water Conservation District v. United States, 424 U.S. 800, 96 S.Ct. 1236, 47 L.Ed.2d 483 (1976). Third, unsettled issues of state law may make unnecessary the determination of federal constitutional issues; in other words, the court should abstain under the Pullman doctrine. See Railroad Commission of Texas v. Pullman Co., 312 U.S. 496, 61 S.Ct. 643, 85 L.Ed. 971 (1941).

I. Burford Abstention.

Generally, the court should exercise the jurisdiction which it is granted; however, in certain, exceptional circumstances, abstention is appropriate. See Arrow v. Dow, 636 F.2d 287, 290 (10th Cir.1980) (citing Colorado River, 424 U.S. at 813, 96 S.Ct. at 1244). One instance when abstention is warranted is “where there have been presented difficult questions of state law bearing on policy problems of substantial public import whose importance transcends the result in the case then at bar.” Colorado River, 424 U.S. at 814, 96 S.Ct. at 1244 (describing different categories of abstention). Abstention in such circumstances has come to be known as “Burford abstention.” Burford was a diversity case to enjoin the enforcement of a state administrative order regarding the drilling of oil wells. The Supreme Court held that abstention was proper because the state had established its own elaborate review system to deal with the complexity of oil field regulation, and review of claims arising under this system by lower federal courts would have an impermissibly disruptive effect on state policy for management of oil fields. Burford, 319 U.S. at 333-334, 63 S.Ct. at 1107; see also Colorado River, 424 U.S. at 814-15, 96 S.Ct. at 1244-45 (explaining Burford).

The Tenth Circuit has upheld Burford abstention by a district court in a case involving the propriety of the Kansas Corporation Commission’s denial of a location exception to drill an oil well near the boundary line of real property. See Robert-Gay Energy Enterprises, Inc. v. State Corporation Commission, 753 F.2d 857 (10th Cir.1985). The Robert-Gay court noted that “Kansas has ‘established its own elaborate review system for dealing with the geological complexities of oil and gas fields,’ ” id. at 860 (quoting Colorado River, 424 U.S. at 815, 96 S.Ct. at 1245 (explaining Burford)), and that “Kansas statutes provide for adequate state court review of orders of the State Corporation Commission_” Id. at 861.

The circuit rejected Burford abstention in a case regarding a state bar commission’s lobbying actions which allegedly deprived the plaintiff/lawyers of constitutional rights. See Arrow v. Dow, 636 F.2d 287 (10th Cir.1980). The Arrow court noted that (1) state law regarding the propriety of the bar commission’s actions was unsettled, making federal impairment of state policy a matter of surmise, and (2) the actions could only be reviewed by application to the state supreme court for a writ [315]*315of mandamus. Id. Thus, Burford was not controlling.

The instant action does not involve a highly technical and complicated subject dealt with in a complex regulatory or statutory scheme. Compare Burford, 319 U.S. 315, 63 S.Ct. 1098 (dealing with oil field regulation); Robert-Gay, 753 F.2d 857 (same). Rather, the Kansas Constitution simply requires the legislature to reapportion voting districts at regular intervals. See Kan. Const, art. 10, § 1. However, the constitution does provide for automatic review of the legislature’s reapportionment by the Kansas Supreme Court. Nonetheless, we do not believe that Burford abstention is proper in this case. The supreme court’s review must occur within forty-five (45) days of the reapportionment, there is no process provided for discovery, and the proceeding before the court is not adversarial. See id.; In re House Bill No. 2620, 225 Kan. 827, 828, 595 P.2d 334, 337 (1979). Moreover, the supreme court reviews the reapportionment not in light of a complicated state regulatory or statutory scheme, but in light of the concept of equal protection embodied in the Fourteenth Amendment to the United States Constitution. See House Bill No. 2620, 225 Kan. at 830, 595 P.2d at 338. Given this, we decline to abstain under Burford from further proceedings in this case.

II. Colorado River Abstention.

The defendants alternatively assert that the court should abstain under the doctrine of Colorado River. Colorado River abstention is intended to avoid duplicative litigation; under it, a federal court may abstain when exceptional circumstances exist. See Colorado River, 424 U.S. 800, 96 S.Ct. 1236. Factors which the court should consider in determining whether exceptional circumstances exist include the order in which the state and federal courts obtained jurisdiction, the convenience of the federal forum, and the desirability of avoiding piecemeal litigation. Id. at 818, 96 S.Ct. at 1246.

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Bluebook (online)
715 F. Supp. 313, 1989 U.S. Dist. LEXIS 7380, 1989 WL 73425, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-county-commissioners-v-hayden-ksd-1989.