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Rooker-Feldman Doctrine Bars Review of State Court Order by District Courts
The Sixth Circuit Court of Appeals affirmed a Michigan federal district court’s order that dismissed an action challenging state court orders that allowed confiscation of a prisoner’s pension benefits for incarceration costs.
Three Michigan prisoners filed this putative class action challenging the conversion of their pension benefits. Pursuant to the State Correctional Facility Reimbursement Act (SCFRA), Mich. Comp. laws § 800.401-406, the State sought reimbursement for incarceration from each plaintiff’s arrests, including pension benefits. Their sentencing court entered an order in the State’s favor. One prisoner appealed, with the Michigan Supreme Court affirming, and the U.S. Supreme Court denying certiorari.
After the district court dismissed their complaint challenging the SCFRA order, the prisoners appealed. The Sixth Circuit said the question is a jurisdictional one, for the district court’s order was based on the Rooker-Feldman doctrine and res judicata.
The Supreme Court is vested with exclusive jurisdiction over appeals from final state court judgments. “The Rooker-Feldman doctrine prevents the lower federal courts from exercising jurisdiction over cases brought by ‘state-court losers’ challenging state-court judgments rendered before the district court proceedings commenced.’” The doctrine applies “only when a plaintiff complains of injury from the state court judgment itself.”
“If the source of the injury is the state court decision, the Rooker-Feldman doctrine would prevent the district court from asserting jurisdiction. If there is some other source of injury, such as a third party’s action, then the plaintiff asserts an independent claim.” Additionally, the Rooker-Feldman doctrine “does not prohibit federal district courts from exercising jurisdiction where the plaintiff’s claim is merely a general challenge to the constitutionality of the state law applied to state action, rather than a challenge to the law’s application in a particular case.”
Here, the Sixth Circuit found the prisoners were challenging the orders as applied to them. Additionally, they challenged the defendants’ actions on those orders. Thus, their claim, as presented, is barred. The lower court, however, would not be prevented “from exercising jurisdiction over their general challenge to the validity of SCFRA.”
The Court also held their general challenge to SCFRA’s validity is barred by res judicata. The Court found that the prior state-court decisions at issue were decided on the merits and involved the same parties, and any due process, Employee Retirement Income Security Act (29 U.S.C. § 1001), or state law arguments were or could have been resolved in the previous actions.
The district court’s order was affirmed. See: Abbott v. Michigan, 474 F.3d 324 (6th Cir. 2006).
Three Michigan prisoners filed this putative class action challenging the conversion of their pension benefits. Pursuant to the State Correctional Facility Reimbursement Act (SCFRA), Mich. Comp. laws § 800.401-406, the State sought reimbursement for incarceration from each plaintiff’s arrests, including pension benefits. Their sentencing court entered an order in the State’s favor. One prisoner appealed, with the Michigan Supreme Court affirming, and the U.S. Supreme Court denying certiorari.
After the district court dismissed their complaint challenging the SCFRA order, the prisoners appealed. The Sixth Circuit said the question is a jurisdictional one, for the district court’s order was based on the Rooker-Feldman doctrine and res judicata.
The Supreme Court is vested with exclusive jurisdiction over appeals from final state court judgments. “The Rooker-Feldman doctrine prevents the lower federal courts from exercising jurisdiction over cases brought by ‘state-court losers’ challenging state-court judgments rendered before the district court proceedings commenced.’” The doctrine applies “only when a plaintiff complains of injury from the state court judgment itself.”
“If the source of the injury is the state court decision, the Rooker-Feldman doctrine would prevent the district court from asserting jurisdiction. If there is some other source of injury, such as a third party’s action, then the plaintiff asserts an independent claim.” Additionally, the Rooker-Feldman doctrine “does not prohibit federal district courts from exercising jurisdiction where the plaintiff’s claim is merely a general challenge to the constitutionality of the state law applied to state action, rather than a challenge to the law’s application in a particular case.”
Here, the Sixth Circuit found the prisoners were challenging the orders as applied to them. Additionally, they challenged the defendants’ actions on those orders. Thus, their claim, as presented, is barred. The lower court, however, would not be prevented “from exercising jurisdiction over their general challenge to the validity of SCFRA.”
The Court also held their general challenge to SCFRA’s validity is barred by res judicata. The Court found that the prior state-court decisions at issue were decided on the merits and involved the same parties, and any due process, Employee Retirement Income Security Act (29 U.S.C. § 1001), or state law arguments were or could have been resolved in the previous actions.
The district court’s order was affirmed. See: Abbott v. Michigan, 474 F.3d 324 (6th Cir. 2006).
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Related legal case
Abbott v. Michigan
| Year | 2006 |
|---|---|
| Cite | 474 F.3d 324 (6th Cir. 2006) |
| Level | Court of Appeals |