Lance v. Dennis
In Lance v. Dennis, 546 U.S. 459 (2006), the U.S. Supreme Court held per curiam that Rooker-Feldman doctrine did not preclude plaintiffs from proceeding in federal court when they were not the parties in a state court proceeding.
Rooker-Feldman doctrine prevents the lower federal courts from exercising jurisdiction over cases brought by "state-court losers" challenging "state-court judgments rendered before the district court proceedings commenced." Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005). In this case, the District Court dismissed plaintiffs' suit on the ground that they were in privity with a state-court loser. The Court held that the Rooker-Feldman doctrine does not bar plaintiffs from proceeding, and vacate the District Court's judgment.
Justice John Paul Stevens wrote the sole dissent, and it was on other independent grounds (issue preclusion). His dissent, however, gave a clear view of his dislike for the Rooker-Feldman doctrine:
- Rooker and Feldman are strange bedfellows. Rooker, a unanimous, three-page opinion written by Justice Van Devanter in 1923, correctly applied the simple legal proposition that only this Court may exercise appellate jurisdiction over state-court judgments. See Rooker v. Fidelity Trust Co., 263 U.S. 413, 416, 44 S. Ct. 149, 68 L. Ed. 362. Feldman, a nonunanimous, 25-page opinion written by Justice Brennan in 1983, was incorrectly decided and generated a plethora of confusion and debate among scholars and judges. See District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 103 S. Ct. 1303, 75 L. Ed. 2d 206; id. at 488, 103 S. Ct. 1303, 75 L. Ed. 2d 206 (STEVENS, J., dissenting). Last Term, in JUSTICE GINSBURG's lucid opinion in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 125 S. Ct. 1517, 161 L. Ed. 2d 454 (2005), the Court finally interred the so-called "Rooker-Feldman doctrine." And today, the Court quite properly disapproves of the District Court's resuscitation of a doctrine that has produced nothing but mischief for 23 years.
- (footnote citing numerous law review articles deleted)