711 F. App'x 419
9th Cir.2018Background
- Santos, a criminal defendant in Guam, sought reconsideration of a Superior Court ruling declining to reexamine the probable-cause basis for a search warrant.
- He sought interlocutory review in the Supreme Court of Guam and was denied.
- Santos then filed a suit in federal district court asking the federal court to order the Superior Court to decide probable cause in the first instance.
- The district court dismissed for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine.
- Santos appealed to the Ninth Circuit, arguing Rooker–Feldman does not bar federal review of nonfinal state-court proceedings.
- The Ninth Circuit affirmed, concluding Santos’s federal suit was a de facto appeal of the Superior Court’s interlocutory decision and thus barred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars the federal suit | Santos: federal court may order Superior Court to decide probable cause; Rooker–Feldman applies only to final judgments | People of Guam: Rooker–Feldman bars federal review of state-court rulings (they also raised Younger abstention) | Rooker–Feldman bars the suit; the federal action is a forbidden de facto appeal |
| Whether Rooker–Feldman applies to interlocutory state-court decisions | Santos: doctrine should not apply to ongoing, nonfinal proceedings | People of Guam: doctrine can apply when federal suit seeks relief from state-court decision | Court: doctrine applies to interlocutory state-court decisions as well |
Key Cases Cited
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (establishes that federal district courts lack appellate jurisdiction over state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (limits lower federal courts from reviewing state-court adjudications)
- Cooper v. Ramos, 704 F.3d 772 (defines de facto appeal and analyzes relief-focused test for Rooker–Feldman)
- Noel v. Hall, 341 F.3d 1148 (discusses de facto equivalent of direct appeal)
- Doe & Assocs. Law Offices v. Napolitano, 252 F.3d 1026 (holds Rooker–Feldman can apply to interlocutory state-court decisions)