Rooker-Feldman vs. Res Judicata in the Third Circuit?
The Rooker-Feldman doctrine has drawn considerable attention recently in the Third Circuit.
Under the traditional application of the Rooker-Feldman doctrine, lower federal courts (such as district and bankruptcy courts) are prohibited from exercising appellate jurisdiction over state court judgments. In other words, federal courts lack subject matter jurisdiction over actions which have already been litigated in state court, or which are deemed "inextricably intertwined" with a previous state court adjudication. A matter is "inextricably intertwined" where the desired federal relief would require either (1) a determination that the state court was wrong; or (2) action by the federal court that would render the state court’s judgment ineffectual (i.e.: would allow the federal plaintiff to undo or prevent enforcement of the state court’s order).
However, in Exxon Mobil v. Saudi Basic Indust., Corp., 544 U.S. 280, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005) slip op here, the Supreme Court seemed to limit the scope of Rooker-Feldman by specifying that the doctrine applies only when the loser of a state court action asks the federal court to review and reject the state court judgments. Stated differently, the "doctrine applies only when a plaintiff asks a district court to redress an injury caused by the state court judgment itself-not when a plaintiff merely seeks to relitigate a claim or issue already litigated in state court." Moncrief v. Chase Manhattan Mortg. Corp., 2008 WL 1813161 (3d Cir. 2008) slip op here.
In the wake of Exxon, Third Circuit courts have been quick to re-affirm their adherence to the Rooker-Feldman paradigm, while simply invoking the doctrine of Res judicata, or claim preclusion, whenever the Exxon limitation may be implicated. In effect, it may be rather difficult to discern claims which are barred by these respective doctrines. Indeed, some recent opinions simply cite the doctrines as alternative rationales for dismissing the same claim. Technically, however, the Rooker-Feldman doctrine bars a federal claim to the extent it seeks to undo or prevent execution of a state court judgment, whereas Res judicata bars a claim to the extent that it seeks to adjudicate all or part of a claim which was, or even could have been, adjudicated in a previous litigation.
It is further worth noting in this context that the Third Circuit has left the door open for Rule 11 sanctions to be imposed upon a plaintiff who persists in pursuit of a federal claim, even after receiving notice that said claim appears to be barred under the Rooker-Feldman doctrine. See Gary v. Braddock Cemetery, 517 F.3d 195 (3d Cir. 2008) slip op here.
