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This document summarizes a dissenting opinion regarding the denial of a writ of certiorari. The dissent argues that the Fourth Circuit improperly applied the Younger abstention doctrine in two ways. First, Younger has never been applied to a case where the state was not a party to pending state proceedings, as in this private child custody dispute. Second, the Fourth Circuit required exhaustion of modification attempts in state court before allowing federal claims, rather than temporarily abstaining as prec

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