Michael Banks v. Francis Slay
2015 U.S. App. LEXIS 10338
| 8th Cir. | 2015Background
- In 2009 Banks and Rush-Banks obtained a $900,000 default judgment in Missouri state court against St. Louis police officer Reginald Williams, entered against him in his individual and official capacities.
- Plaintiffs sought a writ of mandamus in state court (and appealed to the Missouri Court of Appeals) to compel the City and Board of Police Commissioners to satisfy that judgment; the Missouri Court of Appeals denied the writ without prejudice and directed pursuit of an original writ in the Missouri Supreme Court under Mo. S. Ct. R. 94.
- Plaintiffs did not seek relief in the Missouri Supreme Court; instead they filed a federal declaratory judgment action asking the Eastern District of Missouri to declare the City and Board obligated to pay the judgment and to issue a writ of mandamus ordering payment.
- Defendants moved to dismiss, arguing lack of federal subject matter jurisdiction under the Rooker-Feldman doctrine, res judicata, and the § 1983 statute-of-limitations; the district court dismissed with prejudice, citing Rooker-Feldman and indicating Younger abstention.
- The Eighth Circuit reversed, holding Rooker-Feldman inapplicable because plaintiffs’ injury derived from defendants’ refusal to satisfy the official-capacity judgment (not the state-court judgment), and Younger abstention inappropriate because there was no pending state proceeding.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman deprives federal court jurisdiction | Banks: federal relief seeks redress for injury caused by defendants' refusal to pay, not to overturn state-court judgment | Defs: federal court must not review or reject state-court judgments; Rooker-Feldman bars suit | Court: Rooker-Feldman inapplicable; plaintiffs not seeking review/rejection of state judgment but relief for independent injury |
| Whether Younger abstention requires dismissal | Banks: no parallel/pending state proceeding; appeal concluded and no petition to Missouri Supreme Court is pending | Defs: federal suit would interfere with state court processes; abstention appropriate | Court: Younger inapplicable because no pending state proceeding; abstention unwarranted |
| Whether mandamus to compel City/Board to pay is barred by state law/procedure | Banks: official-capacity judgment is against municipality/Board and federal court can declare/compel payment | Defs: state law provides no authority to require City/Board to pay a judgment entered solely against officer; state procedures control | Court: did not resolve merits here; federal jurisdiction exists to decide claims (remanded) |
| Whether dismissal with prejudice was proper | Banks: dismissal barred federal adjudication of their substantive relief; improper where jurisdiction exists | Defs: procedural/threshold defenses justified dismissal | Court: dismissal with prejudice was error given jurisdictional and abstention rulings; case remanded for further proceedings |
Key Cases Cited
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (Rooker-Feldman principles described)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (federal courts lack appellate jurisdiction over state court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (limits Rooker-Feldman to cases where plaintiff is a state-court loser seeking review/rejection of state judgment)
- Younger v. Harris, 401 U.S. 37 (1971) (federal courts must abstain when exceptional parallel state proceedings threaten undue interference)
- Sprint Communications, Inc. v. Jacobs, 134 S. Ct. 584 (2013) (clarifies categories of state proceedings that trigger Younger abstention)
- Edwards v. City of Jonesboro, 645 F.3d 1014 (8th Cir. 2011) (distinguishes injuries caused by underlying events from injuries caused by state-court judgments for Rooker-Feldman)
- Sulik v. Taney County, Mo., 393 F.3d 765 (8th Cir. 2005) (statute-of-limitations guidance for § 1983 actions)
- Dodson v. Univ. of Ark. for Med. Scis., 601 F.3d 750 (8th Cir. 2010) (discussion of Rooker-Feldman boundaries)