Summary
This Eighth Circuit opinion addresses whether federal claims alleging a conspiracy related to state-court proceedings are barred by the Rooker-Feldman doctrine. The court concludes that the doctrine does not apply because the plaintiffs seek damages for the defendants' independent wrongful acts rather than asking the federal court to overturn a state-court judgment. Accordingly, the appellate court vacates the district court's dismissal and remands the case for further proceedings.
Topics
Practice areas
Questions Presented
- Whether the Rooker‑Feldman doctrine applies to the plaintiffs' federal claims alleging a conspiratorial scheme involving state‑court judges and parties.
Holdings
- Claims arising out of an alleged state‑court conspiracy can escape dismissal under the Rooker‑Feldman doctrine.
Key quotations
“The answer is yes, so we vacate the district court’s order to the contrary and remand for further proceedings.”
Factual background
The plaintiffs, a law firm and its partners, withdrew from a state‑court wrongful‑death case after the state court found misconduct and dismissed the case with prejudice. The firm alleges that state‑court judges and opposing parties conspired to obtain sanctions against the firm. The federal suit seeks damages and declaratory relief based on alleged First Amendment and due‑process violations.
Procedural history
The district court dismissed the plaintiffs' federal claims alleging a conspiratorial scheme by state‑court judges and parties, holding that the Rooker‑Feldman doctrine barred the action. The plaintiffs appealed, arguing that the doctrine does not apply because they are not state‑court losers and their claims do not seek to overturn a state‑court judgment.
Remand instructions
Vacate the district court’s dismissal order and remand for further proceedings consistent with this opinion.