Stewart Merritts, Jr. v. Leslie Richards, 62 F.4th 764

Background

PennDOT sought two small easements (1,150 sq ft and a 2-year construction easement of 2,896 sq ft) on Stewart Merritts’s 1.5-acre parcel for drainage work on US Route 22; it offered $400 and $100, which Merritts rejected.
PennDOT filed a declaration of taking and an in rem condemnation action in Pennsylvania state court; after preliminary-objection proceedings (which cannot resolve compensation), the Court of Common Pleas and the Commonwealth Court ruled for PennDOT and a writ of possession issued.
Merritts missed the deadline to seek Pennsylvania Supreme Court review, then sued in federal court under 42 U.S.C. § 1983 against Pennsylvania, PennDOT, and three PennDOT officials (official and individual capacities) seeking damages, injunctive and declaratory relief, and state-law claims.
The District Court dismissed all claims with prejudice: official-capacity claims barred by the Eleventh Amendment and the remainder (individual-capacity claims) dismissed under Burford abstention.
The Third Circuit (this opinion) holds: (1) individual-capacity § 1983 damages claims premised on denial of just compensation should not have been dismissed and must be adjudicated on remand; (2) official-capacity injunctive/declaratory claims fail under Ex parte Young because Merritts seeks relief for past discrete actions, not ongoing prospective relief; (3) individual-capacity § 1983 claims that seek to challenge the legality of the condemnation judgment are barred by Rooker–Feldman and must be dismissed; and (4) dismissals on Eleventh Amendment and Rooker–Feldman grounds should be without prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ex parte Young permits injunctive/declaratory official-capacity § 1983 suits	Merritts: Ex parte Young allows federal injunctive/declaratory relief to stop PennDOT officials from possessing or asserting title and from denying just compensation	Defendants: Eleventh Amendment bars official-capacity relief because Ex parte Young applies only to prospective relief for ongoing violations	Held: Ex parte Young does not apply—Merritts seeks relief for discrete past acts (reparative relief), not prospective relief; official-capacity claims barred by Eleventh Amendment and must be dismissed (without prejudice).
Whether Burford abstention permits dismissal of individual-capacity § 1983 damages claims	Merritts: District Court should not abstain and must decide his § 1983 damages claims	Defendants: Federal court should abstain under Burford to avoid interfering with state eminent-domain process	Held: Burford does not permit dismissal of damages claims; abstention cannot be used to dismiss § 1983 damage actions.
Whether Rooker–Feldman bars federal review of claims challenging the legality of the condemnation (unlawful acquisition, seizure, due process)	Merritts: His § 1983 claims challenge defendants’ conduct and constitutional violations, not merely the state judgment	Defendants: The state condemnation judgment caused Merritts’s injuries; federal suit improperly seeks appellate review of that judgment	Held: Rooker–Feldman applies—Merritts is a state-court loser as to acquisition claims, the state judgment was effectively final, and his unlawful-acquisition claims invite review/rejection of that judgment; those claims are jurisdictionally barred (dismissed without prejudice).
Whether just-compensation § 1983 damages claims are barred by Rooker–Feldman or otherwise	Merritts: Claims for denial of just compensation and conspiracy to deny compensation can proceed in federal court against officials individually	Defendants: Those claims are foreclosed by the state-court condemnation proceedings or by sovereign-immunity/abstention doctrines	Held: Rooker–Feldman does not bar just-compensation claims because compensation was not resolved in the condemnation proceeding; just-compensation damage claims against officials in their individual capacities must be adjudicated on remand (other defenses like qualified immunity left for District Court).

Key Cases Cited

Ex parte Young, 209 U.S. 123 (U.S. 1908) (official-capacity suits for prospective injunctive relief may avoid Eleventh Amendment immunity)
Verizon Md., Inc. v. Pub. Serv. Comm’n of Md., 535 U.S. 635 (U.S. 2002) (Ex parte Young requires an ongoing violation and prospective relief)
New Orleans Pub. Serv., Inc. v. Council of City of New Orleans, 491 U.S. 350 (U.S. 1989) (Burford abstention protects complex state administrative processes)
Papasan v. Allain, 478 U.S. 265 (U.S. 1986) (Ex parte Young focuses on ongoing, not wholly past, violations)
Edelman v. Jordan, 415 U.S. 651 (U.S. 1974) (Eleventh Amendment bars federal awards that are functionally retrospective monetary relief against the state)
Coeur d’Alene Tribe of Idaho v. Idaho, 521 U.S. 261 (U.S. 1997) (limitations on Ex parte Young for claims affecting state land ownership)
Quackenbush v. Allstate Ins. Co., 517 U.S. 706 (U.S. 1996) (abstention cannot be used to dismiss damages actions)
Burford v. Sun Oil Co., 319 U.S. 315 (U.S. 1943) (foundational decision on Burford abstention)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (federal courts lack authority to exercise appellate review of state-court judgments)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (Rooker–Feldman limits lower federal-court review of state judicial decisions)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (clarifies Rooker–Feldman requirements)
Knick v. Township of Scott, 139 S. Ct. 2162 (U.S. 2019) (a taking gives rise to a federal claim for just compensation upon the taking)
La. Power & Light Co. v. City of Thibodaux, 360 U.S. 25 (U.S. 1959) (discusses abstention in the eminent-domain context)
County of Allegheny v. Frank Mashuda Co., 360 U.S. 185 (U.S. 1959) (limits abstention when plaintiff seeks damages)
Malhan v. Sec’y U.S. Dep’t of State, 938 F.3d 453 (3d Cir. 2019) (state-court judgment is "effectively final" for Rooker–Feldman when appeal time has expired)
Great W. Mining & Min. Corp. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (discusses Rooker–Feldman framework)