785 F. Supp. 2d 579
E.D. La.2011Background
- This civil rights action arises from Storyville subtenants allegedly conspired with state actors to remove them after a state eviction proceeding for a mechanical bull.
- The Canal Street Development Corporation (CSDC) and 800 Canal Street sued in state court for eviction based on subtenant conduct and zoning violations.
- The state court found the mechanical bull violated the city’s Comprehensive Zoning Ordinance and the sublease, prompting appeals and related state litigation.
- Storyville and related subtenants filed a federal complaint alleging §1983/§1985/§1986 violations and state-law claims, claiming a conspiracy and due-process/equal-protection harms.
- Defendants moved to dismiss under Rooker-Feldman, or abstain/stay under Colorado River; the court considered jurisdiction and abstention options.
- The court ultimately granted in part and denied in part, staying the federal case to await resolution of parallel state proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars this federal suit | Storyville asserts federal claims are independent of state ruling | Defendants contend suit seeks review of state judgment | Rooker-Feldman does not bar jurisdiction at this stage |
| Whether Colorado River abstention applies and a stay is proper | Federal court should proceed despite state appeals | Federal court should abstain due to parallel state proceedings | Colorado River abstention applies; stay granted; case administratively closed for statistics |
Key Cases Cited
- United States v. Shepherd, 23 F.3d 923 (5th Cir.1994) (limits of federal jurisdiction over state-court judgments)
- Liedtke v. State Bar of Texas, 18 F.3d 315 (5th Cir.1994) (Rooker-Feldman applied to state-court judgments)
- Hale v. Harney, 786 F.2d 688 (5th Cir.1986) (state-court judgments on appeal still reviewable in state system; no federal review)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (limits of Rooker-Feldman; finality of state proceedings required)
- Feldman v. Home Installment Co., 460 U.S. 462 (1983) (Rooker-Feldman doctrine scope and purpose)