Facts
- Exxon (later Exxon Mobil) affiliates and Saudi Basic Industries Corp. (SABIC) formed joint ventures to produce polyethylene in Saudi Arabia.
- A dispute arose over alleged overcharges in royalties for sublicenses to a polyethylene manufacturing process.
- In July 2000, SABIC filed suit in Delaware state court seeking a declaration that its royalty charges were proper.
- Shortly afterward, Exxon entities filed a federal action in the District of New Jersey asserting substantially the same overcharge claims and invoking federal jurisdiction under 28 U.S.C. § 1330.
- Exxon later asserted counterclaims in the Delaware action mirroring its federal claims.
- The Delaware case proceeded to trial first; the jury returned a verdict exceeding $400 million for Exxon, and SABIC appealed to the Delaware Supreme Court.
- In the federal case, SABIC moved to dismiss; the district court denied the motion.
- On interlocutory appeal, the Third Circuit raised Rooker-Feldman on its own and dismissed for lack of jurisdiction, reasoning that the federal case would effectively seek review of the state-court judgment.
Issues
- Whether the Rooker-Feldman doctrine strips a federal district court of subject-matter jurisdiction when a parallel state case has produced a judgment on overlapping claims.
- Whether Rooker-Feldman applies when the federal action was filed before the state-court judgment and does not seek appellate-type review and rejection of that judgment.
Decision
- The Supreme Court unanimously reversed the Third Circuit and remanded.
- Rooker-Feldman did not bar the federal action because it was filed before the state-court judgment and did not invite the federal court to review and reject that judgment.
- Any effect of the state-court adjudication on the federal case is addressed through ordinary preclusion principles (and potentially abstention), not a jurisdictional dismissal under Rooker-Feldman.
Legal Principles
- Rooker-Feldman is confined to cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the federal district court proceedings began and seeking federal district court review and rejection of those judgments.
- The doctrine derives from the allocation of appellate review of state-court judgments to the Supreme Court under 28 U.S.C. § 1257; federal district courts exercise original, not appellate, jurisdiction.
- Overlap between state and federal litigation does not itself eliminate federal jurisdiction; once a state judgment is final, its effect is handled through preclusion law rather than Rooker-Feldman.
- Rooker-Feldman is distinct from res judicata and collateral estoppel and should not be used as a substitute for those defenses.
Conclusion
The Court limited Rooker-Feldman to a narrow set of de facto appeals from already-rendered state judgments, holding that parallel state proceedings—even those culminating in a judgment on overlapping claims—do not, without more, deprive federal district courts of subject-matter jurisdiction.