In re Pa., Dep't of Transp.
351 F. Supp. 3d 943
W.D. Pa.2018Background
- Merritts owned 1.5 acres in Frankstown Twp.; PennDOT sought a small right-of-way (temporary construction easement ~3,000 sq. ft. and drainage easement ~1,150 sq. ft.) and offered $500; Merritts rejected the offer.
- PennDOT filed a Declaration of Taking; the Blair County Court of Common Pleas granted PennDOT a writ of possession after briefs, argument, and an evidentiary hearing; the Commonwealth Court affirmed.
- Merritts removed the case to federal court 30 days after the Commonwealth Court decision; PennDOT did not contest removal or appear in federal court.
- Merritts sought injunctive and declaratory relief in federal court, arguing Fourteenth Amendment due-process defects and challenging PennDOT’s authority to condemn.
- The district court remanded, holding (1) Rooker–Feldman bars jurisdiction, (2) Burford abstention counsels against exercising jurisdiction, and (3) Merritts failed to establish federal jurisdiction under the well-pleaded complaint rule; Merritts moved for reconsideration, which the court denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Rooker–Feldman | Merritts: federal claims not actually litigated in state court; state court lacked final judgment; he seeks only prospective relief; unique title history removes case from doctrine | PennDOT: Merritts lost in state court, claims attack state-court judgment and seek to overturn it | Rooker–Feldman applies; federal court lacks subject-matter jurisdiction |
| Burford abstention | Merritts: district court relied on non‑precedential authority; Burford inapplicable to equitable relief | PennDOT: important state interests and procedures in eminent domain justify abstention | Burford abstention proper; district court appropriately declined to exercise jurisdiction |
| Pleading standard / Pro se construction | Merritts: pleadings should be construed liberally; notice of federal issues via PennDOT filings and federal funding | Court: pro se liberality does not relax jurisdictional requirements; federal question not present on face of state complaint; federal funding alone insufficient | Pro se status does not cure lack of jurisdiction; well‑pleaded complaint rule not satisfied |
| Timeliness and propriety of removal | Merritts: removal timely and proper; invoking federal jurisdiction by raising constitutional claim | PennDOT: removal improper; even if proper, Rooker–Feldman and Burford bar or counsel remand | Even if removal were timely, the court would remand for lack of jurisdiction and/or abstain; motion for reconsideration denied |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (establishes that federal district courts lack appellate jurisdiction over state court decisions)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (federal courts cannot review final state court judgments in appellate capacity)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (clarifies scope of Rooker–Feldman and distinguishes independent federal claims)
- Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (applies Rooker–Feldman framework in Third Circuit)
- Walker v. Horn, 385 F.3d 321 (3d Cir. 2004) (explains when raising new constitutional theories in federal court is barred by Rooker–Feldman)
- Burford v. Sun Oil Co., 319 U.S. 315 (U.S. 1943) (authorizes abstention where federal adjudication would interfere with difficult state regulatory schemes)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (U.S. 1998) (jurisdictional limits: without jurisdiction the court must dismiss)
- Merrell Dow Pharmaceuticals Inc. v. Thompson, 478 U.S. 804 (U.S. 1986) (well‑pleaded complaint rule: federal question must appear on complaint’s face)