Robins v. Ritchie
2011 U.S. App. LEXIS 1577
8th Cir.2011Background
- Robins et al. sued Minnesota officials challenging Article VI, §8, Minnesota Constitution, and Mn. Stat. §204B.36(5) and §490.125 as unconstitutional; sought a preliminary injunction to force an election for Chief Justice in 2010.
- Claims center on resignations/appointments of Minnesota Chief Justices starting 2000 and the alleged pattern to delay elections by appointment.
- Minnesota Supreme Court decisions Clark I (2008) and Clark II (2010) held no constitutional requirement for elections and that vacancies may be filled by appointment until the next general election; Secretary of State was not authorized to post a 2010 election.
- Robins filed suit May 17, 2010; district court denied preliminary injunction; on appeal, the Eighth Circuit held it lacked subject matter jurisdiction under Rooker-Feldman, remanding to dismiss the state-law/constitutional challenges to §8 and §204B.36.
- The majority’s disposition includes remanding Robins’s challenge to §490.125 for dismissal, with a separate concurrence (Beam) addressing standing and alternative grounds for dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman strips jurisdiction over the state-law/constitutional challenges | Robins argues federal review is proper | State contends claims are impermissible under Rooker-Feldman | Yes;-dismissed for lack of jurisdiction under Rooker-Feldman |
| Whether challenges to Article VI, §8 and §204B.36 are inextricably intertwined with state-court decisions | Challenges hinge on state-law mandates for elections | State-court rulings foreclose federal review | Yes;claims intertwined and cannot be adjudicated in federal court |
| Whether the timing of the state-court judgment triggers Rooker-Feldman | Federal suit filed before formal judgment, after Clark II opinion | Rooker-Feldman applies based on final resolution of state claims | Yes; May 13, 2010 (Clark II filing) is final resolution for timing purposes |
| Whether Minn. §490.125 (mandatory retirement age) is cognizable under Rooker-Feldman or standing | §490.125 creates midterm vacancies and infringes rights | Claims are subsumed by state-court decisions; lack standing/merit | Concurred that claim is intertwined and dismissed; Beam would remand for 12(b) analysis; overall result stands |
| Whether Robins had standing to challenge the retirement-age statute | Beam concurs in result but disagrees on standing reasoning; majority treats as intertwined and dismisses |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus., 544 U.S. 280 (U.S. 2005) (redefined Rooker-Feldman timing and scope)
- Rooker v. Fid. Trust Co., 263 U.S. 413 (U.S. 1923) (established core doctrine of exclusive Supreme Court review of state judgments)
- Dist. of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (limits federal review of state-court decisions; finality matters)
- Dodson v. Univ. of Ark. for Med. Scis., 601 F.3d 750 (8th Cir. 2010) (applies Rooker-Feldman to state-court losers in § 1983 actions)
- Charchenko v. City of Stillwater, 47 F.3d 981 (8th Cir. 1995) (discusses when federal claims are intertwined with state-court decisions)
- Bonas v. Town of N. Smithfield, 265 F.3d 69 (1st Cir. 2001) (disenfranchisement occurs when elections are not held as required by law)