This month marks the second anniversary of the Supreme Court’s unanimous decision in Exxon Mobile Corp. v. Saudi Basic Indus. Corp., a decision some thought narrowed the Rooker-Feldman doctrine to the point of near nonexistence. In the face of some Circuit Courts’ expansive interpretation of the doctrine, the Supreme Court said:
When there is parallel state and federal litigation, Rooker-Feldman is not triggered simply by the entry of judgment in state court. This Court has repeatedly held that "the pendency of an action in the state court is no bar to proceedings concerning the same matter in the Federal Court having jurisdiction." Comity or abstention doctrines may, in various circumstances, permit or require the federal court to stay or dismiss the action in favor of state-court litigation. But neither Rooker nor Feldman supports the notion that properly invoked concurrent jurisdiction vanishes if a state court reaches judgment on the same or related question while the case remains sub judice in a federal court.
Despite Saudi Basic, Circuit Courts have found occassion to dismiss federal court actions under Rooker-Feldman. Here are a few examples:
Industrial Comm. & Elect. Inc. v. Monroe County 2005 WL 1253881 (11th Cir): Plaintiff lost Florida state court suit in which it sought declaratory and injunctive relief from a county moratorium against communication towers over a certain height. Plaintiff then filed suit in federal district court and the district court dismissed on res judicata grounds. The Eleventh Circuit vacated the judgment of the district court and remanded the case to district court with orders to dismiss because the district court lacked subject matter jurisdiction under the Rooker-Feldman doctrine.
Federacion de Maestros v. Junta de Relaciones del Trabajo (1st Cir): Puerto Rican union was the target of a grievance before the Purerto Rican Labor Relations Board. The Union moved to dismiss the grievance on grounds of federal labor law preemption. The Board denied the motion to dismiss and this decision was affirmed by both the Puerto Rican court of appeals and Supreme Court on interlocutory appeal. After losing the interlocutory appeal, the Union filed suit against the Board in Puerto Rico federal district court. The First Circuit affirmed dismissal federal district court’s dismissal of the suit under the Rooker-Feldman doctrine.
McCormick V. Braverman (6th Cir.): Plaintiff lost a quiet title action in Michigan state court. She filed suit in federal district court claiming that the administrators of the estate of the previous landowner had violated her constitutional rights. The Sixth Circuit affirmed the district court’s dismissal on Rooker-Feldman grounds.
Do you think these decisions are consistent with the Rooker-Feldman doctrine as it exists post-Saudi Basic?