606 F. App'x 725
5th Cir.2015Background
- Brothers Michael and Steve Houston disputed inheritance interests from their father and grandfather, involving a DeSoto Parish, Louisiana tract and competing probates in Illinois and Louisiana.
- Daisy Cotton (and later her executor/administrator Venneta Queen/Joyce Ross) sought probate/possession; Louisiana state courts (42nd JDC) entered a judgment of possession in favor of Cotton’s estate on February 25, 2013.
- The Houstons filed multiple writ applications in Louisiana that were denied without written opinions; the state litigation record is partially unclear but the possession judgment had been entered and writs were denied before the federal filing.
- In September 2013 the Houstons filed a pro se federal complaint seeking declaratory and injunctive relief to nullify or enjoin enforcement of the Louisiana possession judgment; defendants moved to dismiss invoking the Rooker–Feldman doctrine.
- The district court dismissed for lack of subject-matter jurisdiction under Rooker–Feldman; the Fifth Circuit affirmed, holding the four-element Rooker–Feldman test satisfied and rejecting the Houstons’ void-ab-initio exception and inadequately supported timing/finality arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars federal review of the state possession judgment | Houstons: their federal suit challenges independent wrongs and some state proceedings remained pending, so federal review is permissible | Defs: Houstons are state-court losers seeking review/reversal of a state judgment entered before the federal suit, so Rooker–Feldman deprives federal courts of jurisdiction | Held: Rooker–Feldman applies — all four Exxon elements satisfied; federal court lacked subject-matter jurisdiction |
| Finality/timing element of Rooker–Feldman (were state proceedings "rendered"?) | Houstons: time to appeal had not expired; they had initiated additional state actions and a petition to annul, so state proceedings were not finally concluded | Defs: possession judgment was entered in Feb 2013 and Louisiana Supreme Court denied writs before federal filing; Houstons failed to show ongoing state proceedings | Held: Houstons failed to meet their burden to show ongoing state proceedings; judgment was final for Rooker–Feldman purposes |
| Void-ab-initio exception to Rooker–Feldman (judgment void for lack of jurisdiction or procured by fraud) | Houstons: state judgment void for want of jurisdiction and procured by fraud, allowing collateral federal attack | Defs: state court determined it had jurisdiction; fraud allegations are conclusory and were rejected by state court; full faith and credit applies | Held: Exception not recognized here/unsupported — state court jurisdictional determinations and fraud findings foreclose the exception |
| Whether claims alleging procedural unfairness, conspiracy, or judicial bias are independent of the state judgment | Houstons: allegations of fraud, conspiracy, due-process violation are independent claims | Defs: those allegations are inextricably tied to reversing the state judgment; relief sought would set aside the state judgment | Held: Such allegations are not independent — Rooker–Feldman bars them because relief would require reversing the state judgment |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (articulates four-element Rooker–Feldman test)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (party asserting federal jurisdiction bears burden to establish it)
- Truong v. Bank of Am., N.A., 717 F.3d 377 (5th Cir. 2013) (standard of review and discussion of independent-claim exception)
- Hale v. Harney, 786 F.2d 688 (5th Cir. 1986) (applies Rooker–Feldman even while state appeal pending)
- Marshall v. Marshall, 547 U.S. 293 (2006) (Full Faith and Credit principles concerning state-court jurisdictional determinations)