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Eleventh reverses district court’s dismissal of claim on subject matter jurisdiction grounds and revises its interpretation of Rooker-Feldman doctrine prohibiting district court review of state court judgments

On August 12, 2021, in Behr v. Campbell, et al., No. 18-12842, the Eleventh Circuit Court of Appeals revisited the doctrine of Rooker-Feldman, which is a jurisdictional doctrine holding that a party who loses a case in state court cannot appeal that loss in federal district court. The plaintiff was involved in a custody dispute involving his minor children and filed a pro se complaint in a Florida state court alleging a variety of federal and state law claims claims against his ex-wife, Child Protective Services, the Palm Beach County DCF and the Palm Beach County School District, among others, leading two of the defendants to remove the action federal court. Just seven days after the removal to federal court, the district court sua sponte entered an order dismissing the case for lack of subject matter jurisdiction. The Rooker-Feldman doctrine, it said, prevented it from reviewing the plaintiff’s claims because they were “presented or adjudicated by a state court” or “‘inextricably intertwined’ with a state court judgment because the district court was in effect being asked to review the determinations by the state that caused two of the plaintiff’s children to be removed from his custody and determine that it was the product of falsified reports. The Eleventh Circuit noted that while it and other federal circuits around the country had expanded the ambit of the Rooker-Feldman doctrine over the years, the U.S. Supreme Court’s decision in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005) restored Rooker-Feldman to its original boundaries, which simply holds that state court litigants do not have a right of appeal in the lower federal courts; they cannot come to federal district courts “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.” The Eleventh Circuit noted that because of Exxon Mobilit abandoned the four-factor test that had previously guided this Circuit’s application of Rooker-Feldman and focused on whether the claim that at its heart challenges the state court decision itself—and not the statute or law which underlies that decision—falls within the doctrine because it complains of injuries caused by state-court judgments and invites review and rejection of those judgments. On that basis, the Court identified several claims raised by the plaintiff that fell outside the boundaries of the Rooker-Feldman doctrine because they involved alleged violations of the plaintiff’s rights that occurred as a part of the state court proceedings, rather than as part of the underlying custody matter, or were otherwise simply unrelated to the underlying state court judgment, and sought money damages rather than seeking to overturn the state court’s child custody judgment. The claims not subject to Rooker-Feldman exclusion included claims that (1) the plaintiff’s due process rights were violated, (2) the plaintiff suffered age discrimination, and (3) an illegal governmental search and seizure occurred at the plaintiff’s home. The Eleventh Circuit accordingly vacated the district court’s dismissal in part and remanded for further proceedings on those claims.

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