"Abstention is appropriate in such circumstances because 'the prospect of undue interference with state proceedings counsels against federal relief." Banks v. Slay, 789 F.3d 919, 923 (8th Cir. 2015).
The Rooker-Feldman doctrine "deprives federal courts of jurisdiction in 'cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.'" Banks v. Slay, 789 F.3d 919, 922 (8th Cir. 2015) (quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005)). The doctrine derives from two Supreme Court cases: District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923).
Other circuits have done the same. See, e.g. , Doe v. Univ. of Ky. , 860 F.3d 365, 369 (6th Cir. 2017) ; Google, Inc. v. Hood , 822 F.3d 212, 222 (5th Cir. 2016) ; Banks v. Slay , 789 F.3d 919, 923 (8th Cir. 2015) ; Sirva Relocation, LLC v. Richie , 794 F.3d 185, 189, 191–93 (1st Cir. 2015) ; Falco v. Justices of the Matrimonial Parts of Sup. Ct. of Suffolk Cty. , 805 F.3d 425, 427–28 (2d Cir. 2015) ; Mulholland v. Marion Cty. Election Bd. , 746 F.3d 811, 815–16 (7th Cir. 2014) ; ACRA Turf Club, LLC v. Zanzuccki , 748 F.3d 127, 129, 132–38 (3d Cir. 2014). We emphasize that federal courts cannot ignore Sprint 's strict limitations on Younger abstention simply because states have an undeniable interest in family law.
The district court initially dismissed the petition for lack of jurisdiction, but we reversed. See Banks v. Slay, 789 F.3d 919, 923 (8th Cir. 2015) (finding district court had jurisdiction). All defendants were sued in their official capacities.
"The doctrine thus occupies a ‘narrow ground’ and does not ‘stop a district court from exercising subject-matter jurisdiction simply because a party attempts to litigate in federal court a matter previously litigated in state court.’ " Banks v. Slay, 789 F.3d 919, 922 (8th Cir. 2015) (quoting Exxon Mobil Corp., 544 U.S. at 284, 293, 125 S.Ct. 1517 ). As previously discussed, the class plaintiffs are not seeking review and rejection of state court judgments nor are the plaintiffs claiming to have suffered harm because of prior state court judgments which have held MCTA constitutional.
Therefore, the threshold question in Younger abstention analysis is whether a state proceeding is, in fact, ongoing. Steffel, 415 U.S. at 461-63; Boyle v. Landry, 401 U.S. 77, 80-81 (1971); Columbian Fin. Corp. v. Stork, 811 F.3d 390, 393 (10th Cir. 2016); see also Winter v. Wolnitzek, ___F.3d___, No. 16-5836/16-5839/16-5841, 2016 WL 4446081, at *2 (6th Cir. Aug. 24, 2016) ("In the absence of an ongoing enforcement action, Younger has no role to play, leaving us with authority, indeed an obligation, to resolve the case"); Banks v. Slay, 789 F.3d 919, 923 (8th Cir. 2015) (holding that abstention was inappropriate because the state appellate case ended and plaintiffs did not petition the state supreme court); ReadyLink Healthcare, Inc. v. State Comp. Ins. Fund, 754 F.3d 754, 759 (9th Cir. 2014) (describing "ongoing" as the first and independent element). This threshold question is necessary because "the relevant principles of equity, comity, and federalism have little force in the absence of a pending state proceeding."
Id. (quoting 15 U.S.C. § 1692e). And in Banks v. Slay, 789 F.3d 919, 922 (8th Cir.2015), we emphasized that the doctrine only applies to “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Id.
1 Davis claims that the Rooker–Feldman doctrine deprives this court of jurisdiction because in the state court proceedings Janson had questioned Basler about the affidavit before judgment was entered. In Banks v. Slay, 789 F.3d 919, 922 (8th Cir.2015), our court pointed out the “proper focus” of the Rooker–Feldman doctrine has been explained by the Supreme Court: it is confined to the narrow ground of barring state court losers from inviting federal review of state court judgments. Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005).
Davis claims that the Rooker–Feldman doctrine deprives this court of jurisdiction because in the state court proceedings Janson had questioned Basler about the affidavit before judgment was entered. In Banks v. Slay, 789 F.3d 919, 922 (8th Cir.2015), our court pointed out the “proper focus” of the Rooker–Feldman doctrine has been explained by the Supreme Court: it is confined to the narrow ground of barring state court losers from inviting federal review of state court judgments. Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005).
Additionally, courts assess the source of a plaintiff's alleged injury when applying Rooker-Feldman. As the Supreme Court highlighted in Exxon Mobil, Rooker-Feldman applies when a plaintiff complains of “injuries caused by state-court judgments.” 544 U.S. at 284 (emphasis added); see also, e.g., Banks v. Slay, 789 F.3d 919, 922 (8th Cir. 2015) (quoting Exxon Mobil Corp.).