Edwards v. City of Jonesboro
2011 U.S. App. LEXIS 14337
| 8th Cir. | 2011Background
- Edwards owned a 30-acre tract in Craighead County, Arkansas, and alleged methane from a nearby landfill invaded his land reducing its value.
- Assessments in 1999, 2002, and 2005 warned against building on the land due to methane; prospective buyers canceled contracts.
- In 2005, Edwards sued the City of Jonesboro and officials in state court asserting inverse condemnation, trespass, nuisance, negligence, strict liability, statutes, constitutional claims, and a reservation of federal rights for later federal suit.
- The state-court judge held there was a taking and awarded $387,500 for land value plus $18,901.60 in taxes; appeal was untimely and judgment final.
- Edwards filed a federal §1983 action on September 28, 2009 asserting various federal claims including a Fifth Amendment Just Compensation claim; the district court dismissed.
- The district court concluded the federal claims were precluded by the state court judgment and barred by Rooker-Feldman.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Rooker-Feldman bar the non-Just-Compensation federal claims? | Edwards argues Rooker-Feldman does not apply to his non-Just-Compensation claims. | City contends Rooker-Feldman prohibits review of state-court judgments. | Rooker-Feldman does not bar Edwards's non-Just-Compensation claims. |
| Is Edwards's Just Compensation claim barred by Williamson County principles? | Edwards contends his Fifth Amendment claim is ripe and not subject to Rooker-Feldman. | City argues Williamson County deeming ripeness precludes federal review. | Williamson County ripeness does not bar the Just Compensation claim in light of precedent requiring analysis viaKnutsou/Knutson line; but see preclusion holding later. |
| Are Edwards's federal and state claims precluded by claim preclusion? | Edwards could pursue federal claims separately; state judgment should not preclude. | City asserts Arkansas claim preclusion bars second federal action based on same events. | Yes; Edwards's claims are barred by Arkansas claim preclusion. |
| Does the reservation of federal rights defeat claim preclusion? | Reservation of federal rights in the state action should avoid preclusion. | Reservation of federal rights does not overcome full faith and credit preclusion. | Reservation of federal rights does not defeat claim preclusion; Edwards is precluded. |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (limits of Rooker-Feldman; narrow application)
- Williamson County Reg'l Planning Comm'n v. Hamilton Bank of Johnson City, 473 U.S. 172 (U.S. 1985) (ripeness for Just Compensation Claim)
- San Remo Hotel, L.P. v. City of S.F., 545 U.S. 323 (U.S. 2005) (reservation of federal rights does not defeat preclusion)
- Knutson v. City of Fargo, 600 F.3d 992 (8th Cir. 2010) (Just Compensation Clause injury is to property loss, not state judgment)
- MSK EyEs, Ltd. v. Wells Fargo Bank, 546 F.3d 533 (8th Cir. 2008) (Rooker-Feldman considerations in the Eighth Circuit)