RLR Investments, LLC v. City of Pigeon Forge, Tenn.
4 F.4th 380
6th Cir.2021Background
- RLR Investments owned two adjacent riverfront tracts in Pigeon Forge; the City sought easements to build a public pedestrian walkway that would impair some parking on Tract 1 and add temporary parking on Tract 2.
- The City filed a Tennessee condemnation petition; the state circuit court held a hearing and issued an order of possession finding a public purpose and authorizing eminent-domain relief.
- The City took possession and built the walkway but did not build the replacement parking on Tract 2; RLR continued to litigate in state court and lost a subsequent motion to rescind the order.
- Before valuation proceedings, RLR filed a federal complaint under the Fifth and Fourteenth Amendments and 42 U.S.C. § 1983 seeking a declaration that the state Order of Possession was unconstitutional and injunctive relief enjoining its enforcement.
- The district court dismissed for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine; on appeal the Sixth Circuit considered whether Exxon abrogated Pieper and whether Rooker–Feldman applies to interlocutory state-court orders.
- The Sixth Circuit affirmed: it concluded RLR sought forbidden review of a state-court judgment and that Pieper remains binding, so Rooker–Feldman barred the federal suit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars federal review of an interlocutory state-court order | RLR: Rooker–Feldman doesn't apply because the state order was interlocutory and not final; Exxon limited Rooker–Feldman to final state-court judgments | City: RLR seeks de facto review of a state-court order issued before the federal suit; Rooker–Feldman bars that relief | Court: Rooker–Feldman applies; plaintiff seeks review of a state-court order issued before filing, so jurisdiction is barred |
| Whether the federal claims principally derive from the state-court order (source-of-injury test) | RLR: § 1983 and constitutional claims are distinct and not mere attempts to appeal the state order | City: The injury flows from the state-court Order of Possession; relief would nullify that order | Court: The source of injury is the state order; RLR asks the district court to declare it unconstitutional and enjoin enforcement, triggering Rooker–Feldman |
| Whether Exxon Mobil v. Saudi Basic Industries abrogated Pieper (which applied Rooker–Feldman to interlocutory orders) | RLR: Exxon confines Rooker–Feldman to final judgments and thus abrogates Pieper | City: Pieper remains binding in the Sixth Circuit; Exxon does not mandate overturning Pieper | Court: Pieper remains binding; Exxon and Pieper can coexist—Rooker–Feldman still bars federal review where the state-court decision preceded the federal filing and is the source of the injury |
| Whether the state trial court's Order of Possession qualifies as a "judgment" for Rooker–Feldman purposes | RLR: The order is interlocutory and not final, so it is not the sort of §1257 judgment | City: The order involved merits findings and thus qualifies as a judicial decision causing injury | Court: The Order was a merits determination (not merely ministerial) and counts as a judgment for Rooker–Feldman purposes |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (establishes that only the Supreme Court reviews state high-court final judgments)
- D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (holds lower federal courts may not directly review state-court judicial decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (confines Rooker–Feldman to cases where state-court judgments preceded federal proceedings and the plaintiff seeks review of those judgments)
- Pieper v. Am. Arbitration Ass'n, Inc., 336 F.3d 458 (6th Cir. 2003) (holds Rooker–Feldman applies to interlocutory and lower-state-court orders)
- McCormick v. Braverman, 451 F.3d 382 (6th Cir. 2006) (applied Rooker–Feldman to an interlocutory state-court order post-Exxon)
- Lance v. Dennis, 546 U.S. 459 (U.S. 2006) (reiterates the narrowness of Rooker–Feldman and frames the doctrine in terms of final state-court judgments)