Fieger v. Ferry

Summary

The Sixth Circuit affirmed dismissal of Geoffrey Fieger’s claims challenging the past recusal decisions of Michigan Supreme Court justices under the Rooker-Feldman doctrine. It reversed dismissal of Fieger’s facial and as-applied constitutional challenges to Michigan’s judicial recusal rule, holding that those forward-looking claims were independent of the prior state-court judgments. The case was remanded for further proceedings.

Holdings

1. Rooker-Feldman barred federal review of Fieger's challenge to the justices' past recusal decisions because that claim sought relief for injuries allegedly caused by state-court judgments and would require review of those decisions.
2. Rooker-Feldman did not bar Fieger's facial or as-applied challenge to the constitutionality of Michigan's recusal rule because the alleged injury was the rule's purported unconstitutionality and future application, not a past state-court judgment.
3. Fieger had standing to pursue declaratory relief because the substantial possibility that his present or future cases would reach the Michigan Supreme Court made the alleged future injury sufficiently real and non-speculative.

Questions Presented

1. Whether Rooker-Feldman barred Fieger's challenge to the Michigan Supreme Court justices' past decisions denying recusal.
2. Whether Rooker-Feldman barred Fieger's facial and as-applied constitutional challenge to Michigan's judicial recusal rule.
3. Whether Fieger had standing to seek declaratory relief concerning the future application of Michigan's recusal rule.

Disposition

reversed_and_remanded