Friday, August 25, 2006

D.D.C. Denies Application for Temporary Injunction on Grounds of Younger and Rooker-Feldman Doctrines

Per Bannum, Inc. v. District of Columbia, 433 F.Supp.2d 1 (D.D.C. Mar 30, 2006) (NO. CIV.A. 05-858 JDB):

[Plaintiff sought a temporary restraining order to prevent defendant District of Columbia from preventing it from operating its community center, despite the fact that the D.C. Superior Court had ordered plaintiff to vacate the premises.]

Granting the relief sought would be squarely at odds with fundamental principles underlying this nation's system of federalism and also with statutory limitations on this Court's jurisdiction. On the first point, it is well-settled that, "except in extraordinary circumstances, a federal court should not enjoin a pending state proceeding that is judicial in nature and involves important state interests," see JMM Corp. v. Dist. of Columbia, 378 F.3d 1117, 1120 (D.C.Cir.2004) (citing Younger v. Harris, 401 U.S. 37 (1971)), and the D.C. Circuit has held that the same rule applies to proceedings of the District of Columbia, id. at 1121-22. This Court does not accept Bannum's argument that such extraordinary circumstances exist here simply by virtue of its asserted inability to appeal the Order to Vacate or otherwise await the outcome of future state proceedings.

As for the second, related reason for this Court's refusal to intervene here, Bannum's TRO application appears to cross into jurisdictional territory forbidden to this Court by the so-called "Rooker-Feldman doctrine," which protects the Supreme Court's exclusive jurisdiction to reverse or modify a state-court judgment that conflicts with the constitution or federal law. Indeed, this application is very close to the "paradigm situation in which Rooker-Feldman precludes a federal district court from proceeding," namely where the losing party in state (or, in this case, District of Columbia) court "repair[s] to federal court to undo [the state court's judgment]." Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005); see also id. at 1521-22 (describing Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), as a "suit commenced in Federal District Court to have a judgment of a state court, adverse to the federal court plaintiffs, 'declared null and void' ")…Simply put, this Court cannot and will not act as a de facto court of appeals for parties aggrieved by unfavorable decisions in the District of Columbia courts.


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