New England Legal Foundation
  • Home
  • About
    • Mission & History
    • Annual Reports
    • Board of Directors
    • State Advisory Councils >
      • Connecticut
      • Maine
      • Massachusetts
      • New Hampshire
      • Rhode Island
      • Vermont
    • Trustees
    • Members
    • Staff
    • Job & Internship Opportunities
  • News & Events
  • Docket
  • Briefs
  • Donate
  • Contact

Exxon Mobil Corp. v. Saudi Basic Indus., Inc.

6/8/2005

 
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.

Comments are closed.

    The Docket

    To obtain a copy of any of NELF's briefs, contact us at info@nelfonline.org.

    Categories

    All
    1st Circuit Court Of Appeals
    2nd Circuit Court Of Appeals
    3rd Circuit Court Of Appeals
    Business Litigation Session
    CT
    CT Superior Court
    CT Supreme Court
    Employer Employee Relationships
    February 2018
    February 2019
    Government Regulation/Administration Of Justice
    MA
    MA Appeals Court
    MA Division Of Administrative Law Appeals
    March 2015
    MA Superior Court
    MA Supreme Judicial Court
    MA US District Court
    ME
    ME Supreme Judicial Court
    NH
    NH Supreme Court
    Property Rights
    RI
    RI Supreme Court
    SCOTUS
    United States Supreme Court
    US Court Of Appeals Federal Circuit
    US District Court ME
    VT
    VT Supreme Court

    RSS Feed

    Archives

    June 2019
    April 2019
    October 2018
    June 2018
    February 2018
    October 2017
    October 2016
    June 2016
    February 2016
    October 2015
    June 2015
    March 2015
    October 2014
    June 2014
    February 2014
    October 2013
    June 2013
    February 2013
    October 2012
    June 2012
    February 2012
    October 2011
    June 2011
    February 2011
    October 2010
    June 2010
    February 2010
    October 2009
    February 2009
    October 2008
    June 2008
    February 2008
    October 2007
    June 2007
    October 2006
    June 2006
    February 2006
    October 2005
    June 2005
    February 2005
    October 2004
    June 2004
    February 2004
    October 2003
    May 2003
    February 2003
    September 2002
    May 2002
    February 2002
    May 2001