Target Media Partners v. Specialty Marketing Corp., No. 16-10141 (11th Cir. 2018)Annotate this Case
The Rooker-Feldman doctrine can not bar a federal suit regarding events occurring long after the entry of a state court decision. Long after a state court lawsuit had been completed between Specialty Marketing and Target Media, Specialty Marketing mailed out a letter including the state court events and trial testimony. Target Media filed a defamation action against Specialty Marketing, seeking injunctive relief and damages. The Eleventh Circuit reversed the district court's dismissal of the defamation case, holding that the district court improperly denied subject matter jurisdiction and erroneously dismissed Target Media's defamation claim on Rooker-Feldman grounds. The court held there was no reasonable opportunity to raise the instant claim in Alabama's state courts, and the claim was not "inextricably intertwined" with the judgment rendered in Alabama court.