## Facts

- Colorado required intrastate passenger motor carriers to obtain a state certificate of public convenience and necessity from the Colorado Public Utilities Commission (PUC).
- Several Denver International Airport shuttle operators held federal interstate operating authority and asserted their largely intrastate shuttle service was permitted as incidental to bona fide interstate service.
- In 1999, the PUC pursued enforcement actions and imposed penalties, asserting the shuttle operators were effectively providing intrastate service without meeting state requirements and without sufficient interstate operations to qualify for incidental intrastate authority.
- Mo’s Express litigated the dispute through state proceedings that ended with the Colorado Supreme Court upholding PUC jurisdiction to assess whether carriers genuinely engaged in qualifying interstate operations and upholding fines.
- After the state judgment, Mo’s Express and additional shuttle operators filed a federal § 1983 action against PUC commissioners in their official capacities seeking prospective declaratory and injunctive relief based chiefly on federal preemption theories.
- The federal district court dismissed for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine, treating the suit as an impermissible attack on the state-court judgment.

## Issues

1. Whether Rooker-Feldman deprived the federal district court of subject-matter jurisdiction over the plaintiffs’ post-judgment federal suit seeking prospective relief.
2. Whether, apart from Rooker-Feldman, claim preclusion or issue preclusion barred Mo’s Express’s federal claims due to its participation in the prior state litigation.
3. Whether nonparty shuttle operators to the state case could proceed with prospective federal claims, subject to any applicable preclusion or privity analysis.

## Decision

- The Tenth Circuit reversed the district court’s blanket jurisdictional dismissal and remanded.
- Rooker-Feldman barred only those claims that complained of injury caused by the state-court judgment and sought federal-court review or rejection of that judgment.
- Prospective challenges to ongoing or future PUC enforcement, as such, were not categorically barred by Rooker-Feldman.
- For Mo’s Express, some claims could still be barred by Colorado preclusion principles even if not jurisdictionally barred.
- For the other shuttle operators who were not parties to the state litigation, Rooker-Feldman generally did not apply; any binding effect of the state judgment turned on preclusion/privity, to be addressed on remand.

## Legal Principles

- Rooker-Feldman is narrow: it applies only when a state-court loser seeks relief for an injury caused by a state-court judgment and effectively asks a federal district court to review and reject that judgment.
- A federal claim that overlaps with issues previously litigated is ordinarily addressed through preclusion doctrines, not by treating the case as outside federal jurisdiction.
- Requests for prospective declaratory or injunctive relief against future enforcement may fall outside Rooker-Feldman, though they remain subject to claim preclusion and issue preclusion based on the prior state adjudication.
- Nonparties to the prior state action are not automatically treated as “state-court losers” for Rooker-Feldman purposes; any restraint on their claims depends on preclusion and privity rules.

## Conclusion

The Tenth Circuit held that the district court had jurisdiction over at least some prospective claims because Rooker-Feldman did not bar the entire suit, and it remanded for claim-by-claim analysis to separate jurisdictionally barred attacks on the state judgment from claims potentially barred by preclusion or resolvable on the merits.


Mo’s Express, LLC v. Sopkin, 441 F.3d 1229 (10th Cir. 2006)