Parallel Federal and State Court Proceedings: The Rooker-Feldman Doctrine and Principles of Intersystem Comity

This article previews the issues and arguments in Exxon Mobil Corp. v. Saudi Basic Industries Corp. on appeal to the Supreme Court during the 2004-05 Term. The primary issue asks the Court to determine whether the Rooker-Feldman doctrine applies to divest a federal court of jurisdiction where a pending state court litigation presents identical claims and issues litigated to a final judgment, and the federal action may be used subsequently to possibly challenge an adverse appellate ruling from the state court judgment. In assessing the appeal, the Supreme Court most likely will re-examine the scope and purpose of the so-called Rooker-Feldman doctrine, a somewhat obscure, judicially-created limitation on federal court jurisdiction. Exxon Mobil is asking the Supreme Court to review whether the Third Circuit’s decision to throw Exxon Mobil out of federal court under the Rooker-Feldman doctrine is a correct application, or an impermissible encroachment on dual federal-state concurrent jurisdiction. The Rooker-Feldman doctrine is a somewhat arcane doctrine familiar to teachers of federal courts, some federal judges, and very few others. Basically, the doctrine expresses a judicially created limitation on lower federal court jurisdiction and on the ability of federal courts to oversee or interfere with the working of state courts. As such, the Rooker-Feldman doctrine embodies a principle of federalism. When federal courts apply the Rooker-Feldman doctrine, it is a recognition of the dual system of federal and state courts, and of the coequal dignity of the two separate court systems. The central legal problem that the Rooker-Feldman doctrine addresses is the ability or authority of federal courts to review state court judicial decisions. The legal system consists of a dual set of federal and state courts. The Exxon appeal to the Supreme Court is significant because it affords the Supreme Court an opportunity to revisit the Rooker-Feldman doctrine and perhaps to supply some even more nuanced analysis concerning when and under what circumstances the doctrine applies to require a lower federal court to decline jurisdiction. Both Exxon Mobil and Saudi Basic agree on the proper description of the Rooker-Feldman doctrine and the cases that form the basis for the doctrine. Both sides disagree, however, concerning whether the Rooker-Feldman doctrine had any applicability in the circumstances in which the parallel litigation developed in the underlying litigation and whether the Third Circuit properly applied the two branches of Rooker- Feldman doctrine. While Exxon's threshold position is that the Rooker-Feldman doctrine does not even apply, Saudi Basic takes the equally interesting position that the Supreme Court should dismiss Exxon's federal case as moot. In the alternative, Saudi argues that Exxon's federal case is legitimately barred by the Rooker-Feldman doctrine, which bars federal relitigation of the same claims adjudicated in state court. As a policy matter, Saudi argues that the Rooker-Feldman doctrine fulfills a critical role in the system of judicial federalism and the interest of judicial comity. Thus, the Rooker-Feldman doctrine ensures that federal courts will not review the work of coequal state courts, "by barring dissatisfied state-court litigants from jumping ship and relitigating claims in federal court." The threshold positions of both parties may complicate the Supreme Court's consideration of this appeal: Exxon says the Rooker-Feldman does not apply, and Saudi Basic says the case is moot. If the Supreme Court agrees with either proposition, then the Court may not reach the merits of the Rooker-Feldman arguments at all. If the Court cannot reach consensus on the applicability of the Rooker-Feldman doctrine, on an idiosyncratic set of facts, this case could possibly result in an "improvidently granted" resolution.