Sutasinee Thana v. Board of License Commissioners
2016 U.S. App. LEXIS 11775
| 4th Cir. | 2016Background
- Thai Palace (a Maryland restaurant) had its alcoholic beverage license conditioned by Board consent orders (2009 and 2012) restricting "go-go" and certain entertainment; the 2012 order expired after three years.
- The Board found violations (go-go performances) and revoked the consent orders and the license after an administrative hearing.
- Thai Palace sought judicial review in Maryland state court; the circuit court affirmed in part and remanded in part; the Maryland Court of Special Appeals later affirmed; the Maryland Court of Appeals denied certiorari.
- Before appealing the circuit-court ruling to the Court of Special Appeals, Thai Palace filed a federal § 1983 action alleging First Amendment violations and seeking injunctive/declaratory relief and compensatory damages.
- The district court dismissed for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine, treating the suit as an improper federal appeal of the state-court judgment.
- The Fourth Circuit reversed, holding the Rooker–Feldman doctrine inapplicable because Thai Palace sued to vindicate injuries caused by a state administrative action (not to obtain appellate review of a state-court judgment) and therefore commenced an independent, concurrent federal action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars Thai Palace's § 1983 suit | Thai Palace: suit challenges Board action and seeks damages; not asking district court to review state-court judgment, so Rooker–Feldman shouldn't apply | Board: federal relief would require rejecting the state-court judgment; district court would be sitting in direct review of the state judgment, so Rooker–Feldman bars it | Rooker–Feldman does not apply: this is an independent federal action challenging state administrative action, not an appeal of a state-court judgment |
| Whether claims are moot because the 2012 consent order expired | Thai Palace: claims include past harm and damages, so not moot | Board: the consent order expired and thus no ongoing controversy | Not moot: compensatory damages for past harm keep the case live |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (establishes that lower federal courts cannot exercise appellate jurisdiction over final state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (limits federal district courts from reviewing state-court judgments denying specific relief)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (restricts Rooker–Feldman to its narrow, original scope and distinguishes it from preclusion)
- Verizon Md., Inc. v. Public Serv. Comm’n of Md., 535 U.S. 635 (Rooker–Feldman does not apply to judicial review of state administrative or executive action)
- Skinner v. Switzer, 562 U.S. 521 (clarifies that district courts retain jurisdiction over independent federal claims even if related issues were litigated in state court)
- Lance v. Dennis, 546 U.S. 459 (describes Rooker–Feldman as confined to state-court losers complaining of injuries caused by state judgments)
- Parsons Steel, Inc. v. First Alabama Bank, 474 U.S. 518 (federal courts must give state-court judgments the same preclusive effect they would have in state court)