Lance v. Dennis

Decision Date21 February 2006
Docket NumberNo. 05-555.,05-555.
Citation546 U.S. 459,126 S. Ct. 1198,163 L. Ed. 2d 1059
PartiesLANCE ET AL. <I>v.</I> DENNIS, COLORADO SECRETARY OF STATE
CourtU.S. Supreme Court

Several rounds of state-court litigation following the 2000 census culminated in a Colorado Supreme Court holding that the state legislature's congressional redistricting plan violated the State Constitution. Subsequently, plaintiffs, Colorado voters, filed a federal-court suit, seeking to require the secretary of state to use the legislature's plan because the State Constitution, as interpreted by the State Supreme Court, violated, inter alia, the Elections Clause of the U.S. Constitution. A three-judge District Court ruled that it had no jurisdiction to hear the claim because the Rooker-Feldman doctrine—which prevents 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—applied to plaintiffs, who were in privity with the Colorado General Assembly, a losing party in the state case. In finding privity, the court reasoned that the preclusion principle that a State's citizens are deemed to be in privity with a state government that litigates a matter of public concern, see, e. g., Washington v. Washington State Commercial Passenger Fishing Vessel Assn., 443 U.S. 658, applied equally in the Rooker-Feldman context.

Held: The Rooker-Feldman doctrine does not bar plaintiffs from proceeding. 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. It applies only in limited circumstances where a party in effect seeks to take an appeal of an unfavorable state-court decision to a lower federal court. Incorporation of preclusion principles into Rooker-Feldman risks turning that limited doctrine into a uniform federal rule governing the preclusive effect of state-court judgments, contrary to the Full Faith and Credit Act.

Jurisdiction noted; 379 F. Supp. 2d 1117, vacated and remanded.

ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

PER CURIAM.

The 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 the plaintiffs' suit on the ground that they were in privity with a state-court loser. We hold that the Rooker-Feldman doctrine does not bar the plaintiffs from proceeding, and vacate the District Court's judgment.

I

This is the latest of several rounds of litigation involving the State of Colorado's congressional redistricting after the 2000 census, under which the State gained a seat in the House of Representatives. Lance v. Davidson, 379 F. Supp. 2d 1117, 1121 (2005). The first round began in May 2001. When the Colorado General Assembly failed to pass a redistricting plan for the 2002 congressional elections by the close of its regular session, a group of Colorado voters asked the state courts to create a plan. The courts agreed, drawing a new map reflecting the additional district. See Beauprez v. Avalos, 42 P.3d 642 (Colo. 2002) (en banc). The 2002 elections were held using this court-ordered plan.

The General Assembly passed its own redistricting plan in the spring of 2003, prompting further litigation—this time about which electoral map was to govern, the legislature's or the courts'. Two suits were filed seeking to enjoin the legislature's plan: an original action in the Colorado Supreme Court by the state attorney general seeking to require the secretary of state to use the court-ordered plan, and a similar action brought in a lower state court by several proponents of the court-ordered plan. 379 F. Supp. 2d, at 1121. After the Colorado General Assembly intervened to defend its plan in the first case, the Colorado Supreme Court held that the plan violated Article V, § 44, of the State Constitution, which the court construed to limit congressional redistricting to "once per decade." People ex rel. Salazar v. Davidson, 79 P. 3d 1221, 1231 (2003) (en banc). It therefore ordered the secretary of state to use the court-created plan. We denied certiorari. 541 U.S. 1093 (2004).

The second suit was removed to federal court by the defendants on the basis of the plaintiffs' federal-law claims. See Keller v. Davidson, 299 F. Supp. 2d 1171, 1175 (Colo. 2004). Once Salazar was decided by the Colorado Supreme Court, the viability of the defendants' counterclaims was the only remaining issue. A three-judge District Court held that the defendants were barred by the Rooker-Feldman doctrine from amending their counterclaims to assert additional challenges to the decision in Salazar. It also held that the defendants' original counterclaims, while not barred by the Rooker-Feldman doctrine, were precluded under Colorado law by the judgment in Salazar. Accordingly, the court dismissed the case.

Finally, this suit: Before the dismissal in Keller, several Colorado citizens unhappy with Salazar filed an action in the District Court seeking to require the secretary of state to use the legislature's plan.1 The plaintiffs argued that Article V, § 44, of the Colorado Constitution, as interpreted by the Colorado Supreme Court, violated the Elections Clause of Article I, § 4, of the U.S. Constitution ("The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof"), and the First Amendment's Petition Clause ("Congress shall make no law ... abridging ... the right of the people . . . to petition the Government for a redress of grievances"). The defendants filed a motion to dismiss, arguing that the Rooker-Feldman doctrine and Colorado preclusion law barred any attack on the Colorado Supreme Court's judgment in Salazar and that the plaintiffs had failed to state a valid Petition Clause claim.

The three-judge District Court ruled that under the Rooker-Feldman doctrine, it had no jurisdiction to hear the Elections Clause claim. 379 F. Supp. 2d, at 1127. The Rooker-Feldman doctrine, the court explained, includes three requirements: (1) "[T]he party against whom the doctrine is invoked must have actually been a party to the prior state-court judgment or have been in privity with such a party"; (2) "the claim raised in the federal suit must have been actually raised or inextricably intertwined with the state-court judgment"; and (3) "the federal claim must not be parallel to the state-court claim." 379 F. Supp. 2d, at 1124. The District Court found the first requirement satisfied on the ground that the citizen-plaintiffs were in privity with the Colorado General Assembly—a losing party in Salazar. Relying on our decisions in Washington v. Washington State Commercial Passenger Fishing Vessel Assn., 443 U.S. 658 (1979), and Tacoma v. Taxpayers of Tacoma, 357 U.S. 320 (1958), the court stated that "when a state government litigates a matter of public concern, that state's citizens will be deemed to be in privity with the government for preclusion purposes." 379 F. Supp. 2d, at 1125. This principle, the court reasoned, applies "with equal force in the Rooker-Feldman context." Ibid. The court went on to conclude that the Elections Clause claim was actually raised in Salazar, or inextricably intertwined with that decision, and was not parallel to the claims presented in Salazar. As to the Petition Clause claim, the court ruled that neither Rooker-Feldman nor Colorado preclusion law prevented the court from proceeding to the merits, but that the plaintiffs failed to state a claim. 379 F. Supp. 2d, at 1132; see Fed. Rule Civ. Proc. 12(b)(6).

The plaintiffs appealed. See 28 U.S.C. § 1253. We now note jurisdiction, and address whether the Rooker-Feldman doctrine bars the plaintiffs from proceeding because they were in privity with a party in Salazar. We conclude it does not, and vacate the judgment of the District Court.

II

This Court is vested, under 28 U.S.C. § 1257, with jurisdiction over appeals from final state-court judgments. We have held that this grant of jurisdiction is exclusive: "Review of such judgments may be had only in this Court." District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983) (emphasis added); see also Atlantic Coast Line R. Co. v. Locomotive Engineers, 398 U.S. 281, 286 (1970); Rooker v. Fidelity Trust Co., 263 U.S. 413, 416 (1923). Accordingly, under what has come to be known as the Rooker-Feldman doctrine, lower federal courts are precluded from exercising appellate jurisdiction over final state-court judgments.

The Rooker-Feldman doctrine takes its name from the only two cases in which we have applied this rule to find that a Federal District Court lacked jurisdiction. In Rooker, a party who had lost in the Indiana Supreme Court, and failed to obtain review in this Court, filed an action in Federal District Court challenging the constitutionality of the state-court judgment. We viewed the action as tantamount to an appeal of the Indiana Supreme Court decision, over which only this Court had jurisdiction, and said that the "aggrieved litigant cannot be permitted to do indirectly what he no longer can do directly." 263 U.S., at 416. Feldman, decided 60 years later, concerned slightly different circumstances, with similar results. The plaintiffs there had been refused admission to the District of Columbia bar by the District of Columbia Court of Appeals, and sought review of these decisions in Federal District Court. Our decision held that to the extent plaintiffs challenged the Court of Appeals d...

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