Thursday, May 04, 2006

Tenth Circuit Holds Rooker-Feldman Doctrine Does Not Apply to Non-parties to the State-court Judgment

Per Mo’s Express, LLC v. Sopkin, 441 F.3d 1229 (10th Cir. Mar. 29, 2006):

. . . Rooker-Feldman precludes federal district courts from effectively exercising appellate jurisdiction over claims “actually decided by a state court” and claims “ ‘inextricably intertwined’ with a prior state-court judgment.” Kenmen Eng'g v. City of Union, 314 F.3d 468, 473 (10th Cir.2002) (citing Rooker, 263 U.S. at 415-16, 44 S.Ct. 149, and Feldman, 460 U.S. at 483 n. 16, 103 S.Ct. 1303).

. . .

This Court has repeatedly held that the Rooker-Feldman doctrine “should not be applied against non-parties” to the state-court judgment. Johnson v. Rodrigues (Orozco), 226 F.3d 1103, 1109 (10th Cir.2000) (citing Johnson v. De Grandy, 512 U.S. 997, 1005, 114 S.Ct. 2647, 129 L.Ed.2d 775 (1994)); Johnson v. Riddle, 305 F.3d 1107, 1116 (10th Cir.2002) (calling this rule “well settled”). . . . The Supreme Court appeared to endorse this view in Exxon Mobil, characterizing its decision in De Grandy as holding that “the doctrine has no application to a federal suit brought by a nonparty to the state suit.” Exxon Mobil, 125 S.Ct. at 1523.

. . .

Exxon Mobil and Lance make the disposition of this appeal straightforward for almost all of the Plaintiffs. Only one of the Plaintiffs, Mo's Express, was a party to the decision of the Colorado Supreme Court in Trans Shuttle. With a possible exception noted in footnote 1, the other Plaintiffs had no connection whatsoever to the Trans Shuttle case. They were not parties, they were not bound by the judgment, and they were neither predecessors nor successors in interest to the parties. The other Plaintiffs were nothing more than competitors of the shuttle operators who were party to Trans Shuttle. That relationship falls far short of the connection necessary under Rooker-Feldman to characterize their action in federal court as an appeal of the state-court judgment.


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