Timothy J. Johnston v. Mortgage Electronic Registration Systems, Inc., et al.
The Rooker-Feldman doctrine prevents "the lower federal courts from exercising jurisdiction over cases brought by 'state-court losers' challenging 'state court judgments rendered before the district court proceedings commenced." Lance v. Dennis, 546 U.S. 429, 460 (2006), quoting Exxon-Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005) ("Exxon-Mobil"). The doctrine applies "where a party in effect seeks to take an appeal of an unfavorable state-court decision to a lower federal court." In Lance v. Dennis, 546 U.S. at 466 ("Lance v. Dennis"), this Court held that "the Rooker-Feldman doctrine does not bar actions by nonparties to the earlier court action simply because, for purposes of preclusion law, they would be considered in privity with a party to the judgment." The question presented is: Does Lance v. Dennis allow a plaintiff to avoid the Rooker-Feldman and sue in federal court by claiming it was not a party to the state court litigation, even when it argues that the state court judgment binds it and it uses the judgment to give it standing in federal court?
Whether the Rooker-Feldman doctrine bars a plaintiff from suing in federal court by claiming it was not a party to the earlier state court litigation, even when it argues the state court judgment binds it and it uses the judgment to give it standing in federal court