Commercial Litigation and Arbitration

Rooker-Feldman Does Not Apply to the Decision of a State Administrative Agency

From Gifford v. Meda, 2010 U.S. Dist. LEXIS 45322 (E.D. Mich. May 10, 2010):

Under the Rooker-Feldman doctrine, "lower federal courts are precluded from exercising appellate jurisdiction over final state-court judgments." Lance v. Dennis, 546 U.S. 459, 463 (2006). The Supreme Court in Lance, and in its prior term in Exxon Mobil Corp. v. Saudi Basic Ind. Corp., 544 U.S. 280 (2005), reined in the use of the Rooker-Feldman doctrine by lower federal courts: "In Exxon Mobil, decided last term, we warned that the lower courts have at times extended the Rooker-Feldman doctrine '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 pursuant to 28 U.S.C. § 1738.'" Lance, supra at 464 (citing Exxon Mobil, supra at 283). Emphasizing the "narrowness" of the doctrine, the Court expressly cautioned that "Rooker-Feldman'has no application to judicial review of executive action, including determinations made by a state administrative agency.'" ***

The Court in Lance also cautioned that privity principles that may otherwise apply to general preclusion rules have no place in the Rooker-Feldman analysis. Refusing to allow defendant to invoke Rooker-Feldman against the plaintiffs in Lance, who clearly were not parties to the underlying state-court action, the Court rejected the district court's finding that defendant was in privity with a party in the earlier state-court matter: "The District Court erroneously conflated preclusion law with Rooker-Feldman. Whatever the impact of privity principles on preclusion rules, Rooker-Feldman is not simply preclusion by another name. . . . The Rooker-Feldman doctrine does not bar actions by nonparties to the earlier state-court judgment simply because, for purposes of preclusion law, they could be considered in privity with a party to the judgment." 546 U.S. at 466. T he Court in Lance left the door open for a possible limited application of Rooker-Feldman to a nonparty, specifically hypothesizing a case where an estate might take a de facto appeal in federal court of a prior state court judgment involving the decedent. Id. at 466 n.2. ***

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