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Exxon Mobil Corp. v. Saudi Basic Indus., Inc.
Protecting a Litigant's Right to Federal Court Review of its Federal Rights Claims
At issue in this case was the scope of the so-called Rooker-Feldman doctrine. The doctrine comes from two cases in which parties who had received final adverse judgments in state court sought to initiate actions in the federal district court, complaining that the state courts had violated their federal rights. In those two instances, the Supreme Court held that the federal suits were impermissible, because federal appellate jurisdiction over state court judgments only exists in the Supreme Court itself, not the lower federal courts. In Exxon Mobil, however the Third Circuit was faced with a different circumstance, namely that of parallel federal and state court actions (where the federal action had been brought before the state court matter had been fully litigated), raising the question whether in those circumstances the plaintiff in the federal action still had the right to litigate its federal claims in federal court even after the state court had rendered a judgment (in Exxon Mobil the state trial court decided the matter while an appeal of the federal court's denial of a motion to dismiss was still pending). The Third Circuit answered in the negative, on the ground that the matter had been fully litigated in the state courts.
NELF joined with Defenders of Property Rights in an amicus merits brief urging reversal of the Third Circuit's decision, arguing that the Rooker-Feldman doctrine should only be applied where the federal case has been brought clearly as an attempt to gain a collateral appeal of a state court judgment, after that judgment has been rendered.
In its decision issued on March 30, 2005, the Supreme Court unanimously agreed with NELF. In the opinion, written by Justice Ginsburg, the Supreme Court held (in summary) that the Rooker-Feldman doctrine is "confined to 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." Accordingly, the Third Circuit's dismissal of the federal claim was improper, and the Supreme Court reversed and remanded the matter.
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