Sutter & Gillham PLLC v. Judy Henry, 24-1071

The case arises from a contentious Arkansas wrongful-death lawsuit involving a teenage boy's death, where Sutter & Gillham PLLC initially represented the boy’s mother before withdrawing.
The state court eventually dismissed the case with prejudice, citing misconduct by the family and their attorneys; Sutter & Gillham disputed the sanctions order but did not appeal the denial of their motion to intervene.
The family later overturned the dismissal on appeal, and the wrongful-death case remains pending in state court.
Sutter & Gillham and its attorneys became involved in additional litigation, including defending against retaliatory lawsuits in state court and bringing a separate federal suit under Section 1983, alleging that opposing parties and their lawyers conspired with the state judge.
The district court dismissed the federal suit under the Rooker-Feldman doctrine (which generally bars federal courts from reviewing state-court judgments), finding the action to be an improper collateral attack on state-court rulings.
The Eighth Circuit reviewed the dismissal de novo to determine the correct application of the Rooker-Feldman doctrine after recent Supreme Court clarification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Rooker-Feldman bar federal claims alleging a state-court conspiracy?	Plaintiffs can seek relief for harm caused by defendants’ conduct even if related to state-court proceedings; the suit targets adverse parties, not a state judgment	Defendants argue that the federal suit is an improper attack on state-court decisions, which could and should have been appealed	Rooker-Feldman does not apply; claims not barred
Whether the federal suit is an appeal of a state-court judgment	Plaintiffs do not seek to declare a state judgment void, only relief for independent actions	Defendants characterize the action as an attack on an appealable state-court judgment	Federal case does not seek to invalidate state judgment
Whether plaintiffs must exhaust state remedies or are bound by preclusion doctrines	Plaintiffs allege direct constitutional violations, not subject to exhaustion requirements	Defendants suggest preclusion and exhaustion bar federal claims	Court declines to address; district court to consider in first instance
Whether plaintiffs have standing based on alleged injuries	Plaintiffs claim reputational and financial harm traceable to defendants’ actions	Defendants argue losses are not fairly traceable to defendants’ conduct	Complaint alleges enough for standing at this stage

Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (clarifies Rooker-Feldman applies only when a federal suit is effectively an appeal from a state-court judgment)
Rooker v. Fid. Tr. Co., 263 U.S. 413 (originates doctrine barring lower federal courts from reviewing state-court judgments)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (extends the doctrine to certain federal suits attacking state judicial decisions)
Minch Fam. LLLP v. Buffalo-Red River Watershed Dist., 628 F.3d 960 (sets de novo review standard for Rooker-Feldman dismissals)
MSK EyEs Ltd. v. Wells Fargo Bank, Nat. Ass’n, 546 F.3d 533 (explains the proper, narrow application of Rooker-Feldman post-Exxon Mobil)
Hageman v. Barton, 817 F.3d 611 (Rooker-Feldman does not apply when the focus is on defendants’ actions, not the judgment)
Johnson v. De Grandy, 512 U.S. 997 (notes doctrine inapplicable to non-parties to the state court action)
Behr v. Campbell, 8 F.4th 1206 (jurisdiction exists for damages based on constitutional violations during state-court proceedings)