Tuesday, January 03, 2006

Eighth Circuit Applies Post-Exxon Mobil Rooker/Feldman Doctrine

Per the Eighth Circuit in Dornheim v. Sholes, 430 F.3d 919 (8th Cir. Dec. 07, 2005)

[T]he Supreme Court has confined application of the Rooker/Feldman doctrine to “cases of the kind from which the doctrine acquired its name: cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon Mobil Corp. v. Saudi Basic Indus., --- U.S. ----, 125 S.Ct. 1517, 1521-22, 161 L.Ed.2d 454 (2005). The basis for the Rooker/ Feldman doctrine is that, other than in the context of habeas claims, federal district courts are courts of original jurisdiction, and by statute they are precluded from serving as appellate courts to review state court judgments, as that appellate function is reserved to the Supreme Court under 28 U.S.C. § 1257. Id. at 1526. Exxon Mobil makes clear that the Rooker/Feldman doctrine precludes federal district court jurisdiction only if the federal suit is commenced after the state court proceedings have ended. See id. at 1527 (“[N]either 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.”); see also Mothershed v. Justices of Supreme Court, 410 F.3d 602, 604-05 n. 1 (9th Cir.2005) (determining whether state-court proceedings were complete as the first step of a post- Exxon Mobil Rooker/Feldman analysis). There is no judgment to review if suit is filed in federal district court prior to completion of the state-court action. Rather, “[d]isposition of the federal action, once the state-court adjudication is complete, would be governed by preclusion law.” Exxon Mobil, 125 S.Ct. at 1527.

The North Dakota District Court issued its final order in the divorce proceedings on August 13, 2003. The juvenile court filed its Order of Disposition in the deprivation proceeding on August 26, 2003. Dornheim appealed both state-court rulings to the Supreme Court of North Dakota, which affirmed the lower court judgment in each appeal on June 30, 2004. The Dornheims commenced this suit in federal court on August 13, 2003. At the time that the Dornheims commenced this federal action, the state court adjudication was not complete. See Mothershed, 410 F.3d at 604-05 n. 1 (noting that the state-court proceeding had ended for Rooker/Feldman purposes when the state supreme court denied the plaintiff's request for a writ of mandamus); Federación de Maestros de Puerto Rico v. Junta de Relaciones del Trabajo de Puerto Rico, 410 F.3d 17, 24 & n. 10 (1st Cir.2005) (concluding that the state proceeding has ended when it becomes appealable under § 1257 because the highest state court has issued its final decision, or when the lower state-court ruling otherwise carries preclusive effect, such as when the parties allow the time for appeal to lapse without filing an appeal in state court). Thus, any effect that the state court rulings might have on this federal action is limited to the application of preclusion law, and the state-court adjudications did not divest the federal district court of jurisdiction under the Rooker/Feldman doctrine. See Exxon Mobil, 125 S.Ct. at 1527. The court erred in holding that it lacked jurisdiction to consider the Dornheims' claims.


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