Edwards v. City of Jonesboro, et al., No. 10-2405 (8th Cir. 2011)
Annotate this CasePlaintiff sued the City of Jonesboro, its mayor, and the members of its city council, alleging that methane gas from a city landfill invaded a tract of land owned by plaintiff and so reduced its value which amounted to a taking of the property by the city. Plaintiff sought just compensation under the Fifth and Fourteenth Amendments, other compensatory damages, punitive damages, and injunctive relief. At issue was whether the district court properly granted defendants' motion to dismiss plaintiff's complaint, holding that plaintiff's claims were barred by issue preclusion and, in the alternative, that the court lacked jurisdiction under the Rooker-Feldman doctrine. The court held that plaintiff's claims did not complain of injuries caused by the state court judgment, but of injuries caused by the invasion of plaintiff's land by methane emanating from the city's landfill. Thus, the Rooker-Feldman doctrine did not apply to those claims. The court found that the parties and the district court focused on issue preclusion, but the court held that the case was more readily resolved based on claim preclusion. Thus, the court held that plaintiff's claims were barred by claim preclusion and that plaintiff did not avoid claim preclusion through the reservation of federal rights that he included in the third amended complaint in the state court action. Accordingly, the judgment of the district court was affirmed.
Court Description: Civil case - Section 1983. Rooker-Feldman doctrine did not apply to the claims related to injuries causes by invasion of plaintiff's land by methane gas emanating from defendant's land fill or to his just compensation claim under the Fifth Amendment; however, the claims were precluded by an earlier state court judgment and plaintiff could not avoid claim preclusion by including language in the state court complaint purporting to reserve his federal rights.
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