Vizion One, Inc. v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedNovember 12, 2025
DocketCivil Action No. 2014-0883
StatusPublished

This text of Vizion One, Inc. v. District of Columbia (Vizion One, Inc. v. District of Columbia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vizion One, Inc. v. District of Columbia, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

) VIZION ONE, INC., ) ) Plaintiff, ) ) v. ) No. 14-cv-883 (TSC) ) ) DISTRICT OF COLUMBIA, ) ) ) Defendant. ) )

MEMORANDUM OPINION

Plaintiff Vizion One, Inc. (“Vizion”), a Medicaid health care provider, brings this case

against Defendant District of Columbia (“the District”), raising various claims concerning actions

the District took to suspend Vizion’s Medicaid payments and terminate its Medicaid Provider

Agreement. See Second Am. Compl., ECF No. 35. The District moved to dismiss, arguing that

prior administrative and court proceedings bar Vizion’s claims here. Def.’s Mot. to Dismiss

(“MTD”), ECF No. 37. Vizion opposed. Pl.’s Opp’n to MTD (“Pl.’s Opp’n”), ECF No. 41. For

the reasons set forth below, the court will GRANT the District’s motion.

I. BACKGROUND

The facts of this case were previously set forth in the court’s prior July 13, 2015 Opinion.

Mem. Op., ECF No. 18. In summary, in 2014 the District’s Department of Health Care Finance

(“DHCF”) suspended Medicaid payments to Vizion, based upon a finding “of a credible allegation

of fraud.” Id. at 1 (citing 42 C.F.R. § 455.23). After the District terminated Vizion’s Medicaid

Provider Agreement and converted Vizion’s license to a provisional status, Mem. Op. at 6, Vizion

challenged these actions in the District’s Office of Administrative Hearings (“OAH”). An OAH Administrative Law Judge (“ALJ”) dismissed the case as untimely brought, and Vizion appealed

to the D.C. Court of Appeals. Id. at 1; OAH Final Order at 1–2, ECF No. 43-1. Vizion

simultaneously filed this suit, alleging Fifth Amendment due process violations and that the

applicable regulations are void for vagueness. Compl. at 7, ECF No. 1.

The District moved to dismiss or for summary judgment, on the grounds that Vizion had

failed to exhaust its administrative remedies due to the pendency of an appeal in the D.C. Court of

Appeals. The District further argued that the applicable federal regulations at 42 C.F.R. §§ 455 et

seq., are not vague and overbroad, that there was no conflict between the federal and D.C.

regulations, and that the District had not violated Vizion’s due process rights. ECF No. 10. The

court granted the District’s motion in part and denied it in part.

This court found that the abstention doctrine set forth in Younger v. Harris, 401 U.S. 37

(1971), applied. That doctrine holds that, absent extraordinary circumstances, federal courts

should abstain from enjoining ongoing state judicial proceedings, involving important state

interests, that afford adequate opportunity to raise federal claims, including constitutional claims.

Id. at 41; J.M.M. Corp. v District of Columbia, 378 F.3d 1117, 1121–25 (D.C. Cir. 2004). It

concluded that this case was similar to J.M.M., in which J.M.M. challenged the District’s

enforcement of zoning regulations and revocation of J.M.M.’s license to operate a video store, in

the OAH and the D.C. Board of Appeals and Review, while also suing in federal court raising the

same injunctive and declaratory relief claims. The D.C. Circuit upheld the district court’s

conclusion that state judicial proceedings provided J.M.M. with an adequate avenue to raise its

constitutional claims as defenses to an enforcement action, and thus dismissal of the claims for

injunctive and declaratory relief was appropriate, while staying the claims for money damages,

2 which could not be raised in the state proceedings. J.M.M., 378 F.3d at 1119, 1121, affirming

J.M.M. Corp. v District of Columbia, 253 F. Supp.2d 15, 17 (D.D.C. 2003). Accordingly, this

court found that Vizion’s claims were similar to those raised in J.M.M., and dismissed Vizion’s

claims for declaratory judgment and injunctive relief. Mem. Op. at 10. The court stayed Vizion’s

claims for money damages, pursuant to 42 U.S.C. § 1983, pending a final ruling by the D.C. Court

of Appeals. Id. at 12; Min. Order (Mar. 16, 2020).

The D.C. Court of Appeals reversed the ALJ’s dismissal of the case based on untimeliness

and remanded the case for a hearing on the merits. OAH Final Order at 1–2. Before the hearing,

the ALJ granted Vizion limited discovery, and the District produced documents related to its

adverse decision. On March 14, 2018, the ALJ held an evidentiary hearing. Id. at 4. The parties

agreed to limit the scope of inquiry DHCF’s February 20, 2014 decision to temporarily suspend

Medicaid payments to Vizion, and whether there was an ongoing fraud investigation of Vizion as

of the hearing date. Id. at 6. Vizion presented no witnesses at the hearing. Id. at 4.

The ALJ issued a final order on June 15, 2018. OAH Final Order at 29. The Order

contained detailed findings of fact, reached after making credibility findings with respect to the

District’s witnesses, and conclusions of law. See id. The ALJ concluded that, pursuant to 42

C.F.R. § 455.23, DHCF properly temporarily suspended Vizion’s Medicaid payments on February

20, 2014, due to suspected fraud and the lack of good cause for an exception to the suspension.

The ALJ also concluded that the investigation of suspected fraud was ongoing as of the March 14,

2018 hearing date. Id. at 29.

Vizion appealed to the D.C. Court of Appeals, which affirmed the ALJ’s decision. D.C.

Ct. App. Op., ECF. No. 31-1. The Court of Appeals noted that following an evidentiary hearing,

3 “[a]n OAH ALJ upheld the suspension, concluding that the allegation of fraud involving Vizion

was credible and that DHCF had properly considered whether good cause existed not to suspend

payments.” Id. at 2. The Court specifically addressed Vizion’s constitutional due process claims,

finding that under 42 C.F.R. § 455.23(a)(2), DHCF was authorized to suspend payments to Vizion

without prior notice. Id. at 4. “‘All Circuits that have addressed the issue have determined that a

temporary suspension of Medicare or Medicaid payments does not implicate due process and that

no pre-suspension hearing is required.’” Id. (quoting ABA, Inc. v. District of Columbia, 40 F.

Supp.3d 153, 167 (D.D.C. 2014)) (cleaned up). Finally, the Court of Appeals rejected Vizion’s

claim that an alleged conflict between District unamended regulations1 authorizing suspension

based on reliable evidence of an overpayment, and federal regulations requiring suspension based

on a “‘credible allegation of fraud,’” rendered the regulations void for vagueness, and found that

DHCF and the ALJ had applied the federal regulations. Id. at 4 (quoting 42 C.F.R. § 455.23(a)(1),

and citing Goudreau v. Standard Fed. Sav. & Loan Ass’n., 511 A.2d 386, 391 (D.C. 1986) (holding

that federal regulations preempt conflicting District of Columbia law)).

The parties informed this court of the Court of Appeals decision in a status report in May

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