|
------------------------------------------------------------
--
AN E-BULLETIN
LEGAL INFORMATION INSTITUTE -- CORNELL LAW SCHOOL
lii\@lii.law.cornell.edu
-------------------------------------------------------------
--
Thank you for your patience during our technical difficulties.
The following decisions are from LII's direct Project HERMES
feed from the Supreme Court.
====================================================
EXXON MOBIL CORP. et al. v. SAUDI BASIC INDUSTRIES
CORP. (No. 031696.)
Argued February 23, 2005Decided March 30, 2005
Decision author: Ginsburg
http://supct.law.cornell.edu/supct/html/03-
1696.ZS.html
====================================================
The Rooker-Feldman doctrine, at issue in this case,
has been applied by this Court only twice, in Rooker
v. Fidelity Trust Co., 263 U.S. 413, and in District
of Columbia Court of Appeals v. Feldman, 460 U.S. 462.
In Rooker, plaintiffs previously defeated in state
court filed suit in a Federal District Court alleging
that the adverse state-court judgment was
unconstitutional and asking that it be declared "null
and void." 263 U.S., at 414415. Noting preliminarily
that the state court had acted within its
jurisdiction, this Court explained that if the state-
court decision was wrong, "that did not make the
judgment void, but merely left it open to reversal or
modification in an appropriate and timely appellate
proceeding." Id., at 415. Federal district courts,
Rooker recognized, are empowered to exercise only
original, not appellate, jurisdictions. Id., at 416.
Because Congress has empowered this Court alone to
exercise appellate authority "to reverse or modify" a
state-court judgment, ibid., the Court affirmed a
decree dismissing the federal suit for lack of
jurisdiction, id., at 415, 417. In Feldman, two
plaintiffs brought federal-court actions after the
District of Columbias highest court denied their
petitions to waive a court Rule requiring D. C. bar
applicants to have graduated from an accredited law
school. Recalling Rooker, this Court observed that the
District Court lacked authority to review a final
judicial determination of the D. C. high court because
such review "can be obtained only in this Court." 460
U.S., at 476. Concluding that the D. C. courts
proceedings applying the accreditation Rule to the
plaintiffs were "judicial in nature," id., at 479482,
this Court ruled that the Federal District Court
lacked subject-matter jurisdiction, id., at 482.
However, concluding also that, in promulgating the bar
admission Rule, the D. C. court had acted
legislatively, not judicially, id., at 485486, this
Court held that 28 U.S.C. 1257 did not bar the
District Court from addressing the validity of the
Rule itself, so long as the plaintiffs did not seek
review of the Rules application in a particular case,
460 U.S., at 486. Since Feldman, this Court has never
applied Rooker-Feldman to dismiss an action for want
of jurisdiction. However, the lower federal courts
have variously interpreted the Rooker-Feldman doctrine
to extend far beyond the contours of the Rooker and
Feldman cases, overriding Congress conferral of
federal-court jurisdiction concurrent with
jurisdiction exercised by state courts, and
superseding the ordinary application of preclusion law
under 28 U.S.C. 1738.
In this case, two subsidiaries of petitioner
Exxon Mobil Corporation formed joint ventures with
respondent Saudi Basic Industries Corp. (SABIC) to
produce polyethylene in Saudi Arabia. When a dispute
arose over royalties that SABIC had charged the joint
ventures, SABIC preemptively sued the two subsidiaries
in a Delaware state court, seeking a declaratory
judgment that the royalties were proper. ExxonMobil
and the subsidiaries then countersued in the Federal
District Court, alleging that SABIC overcharged them.
Before the state-court trial, which ultimately yielded
a jury verdict of over $400 million for the ExxonMobil
subsidiaries, the District Court denied SABICs motion
to dismiss the federal suit. On interlocutory appeal,
over eight months after the state-court jury verdict,
the Third Circuit, on its own motion, raised the
question whether subject-matter jurisdiction over the
federal suit failed under the Rooker-Feldman doctrine
because ExxonMobils claims had already been litigated
in state court. The court did not question the
District Courts subject-matter jurisdiction at the
suits outset, but held that federal jurisdiction
terminated when the Delaware court entered judgment on
the jury verdict.
Held: The Rooker-Feldman doctrine is confined to cases
of the kind from which it acquired its name: cases
brought by state-court losers complaining of injuries
caused by state-court judgments rendered before the
federal district court proceedings commenced and
inviting district court review and rejection of those
judgments. Rooker-Feldman does not otherwise override
or supplant preclusion doctrine or augment the
circumscribed doctrines allowing federal courts to
stay or dismiss proceedings in deference to state-
court actions. Pp. 1013.
(a) Rooker and Feldman exhibit the limited
circumstances in which this Courts appellate
jurisdiction over state-court judgments, 1257,
precludes a federal district court from exercising
subject-matter jurisdiction in an action it would
otherwise be empowered to adjudicate under a
congressional grant of authority. In both cases, the
plaintiffs, alleging federal-question jurisdiction,
called upon the District Court to overturn an
injurious state-court judgment. Because 1257, as long
interpreted, vests authority to review a state-court
judgment solely in this Court, e.g., Feldman, 460
U.S., at 476, the District Courts lacked subject-
matter jurisdiction, see, e.g., Verizon Md. Inc. v.
Public Serv. Commn of Md., 535 U.S. 635, 644, n. 3.
When there is parallel state and federal litigation,
Rooker-Feldman is not triggered simply by the entry of
judgment in state court. See, e.g., McClellan v.
Carland, 217 U.S. 268, 282. Comity or abstention
doctrines may, in various circumstances, permit or
require the federal court to stay or dismiss the
federal action in favor of the state-court litigation.
See, e.g., Colorado River Water Conservation Dist. v.
United States, 424 U.S. 800. But neither Rooker nor
Feldman supports the notion that properly invoked
concurrent jurisdiction vanishes if a state court
reaches judgment on the same or a related question
while the case remains sub judice in a federal court.
Disposition of the federal action, once the state-
court adjudication is complete, would be governed by
preclusion law. Under 28 U.S.C. 1738 federal courts
must "give the same preclusive effect to a state-court
judgment as another court of that State would give."
Parsons Steel, Inc. v. First Alabama Bank, 474 U.S.
518, 523. Preclusion is not a jurisdictional matter.
See Fed. Rule Civ. Proc. 8(c). In parallel litigation,
a federal court may be bound to recognize the claim-
and issue-preclusive effects of a state-court
judgment, but federal jurisdiction over an action does
not terminate automatically on the entry of judgment
in the state court. Nor
|
| |
| |
|
