Miller v. Dunn, No. 20-11054 (5th Cir. 2022)
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Plaintiff filed suit in federal court against his ex-wife, two state judges, and several others under 42 U.S.C. Section 1983. The district court sua sponte dismissed the case for lack of subject matter jurisdiction under the Rooker-Feldman doctrine, pointing to related state court proceedings pending on appeal.
On appeal, Plaintiff argued that the district court erred in dismissing his suit under Rooker-Feldman because the relevant state-court cases were pending on appeal when he filed this lawsuit. The Fifth Circuit agreed and reversed the district court’s judgment finding. The court explained that in denying Plaintiff’s motion for reconsideration, the district court relied on Hale and the court’s unpublished Houston decision.” The court concluded that Hale is no longer good law after Exxon Mobil and hold that Rooker-Feldman is inapplicable where a state appeal is pending when the federal suit is filed. The court further reasoned that the Supreme Court has repeatedly emphasized that Rooker-Feldman is a “narrow” jurisdictional bar. It applies only to cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.
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