Brief Fact Summary.
A federal suit between Saudi Basic Industries Corporation and Exxon Mobil Corporation was dismissed when a Delaware state court rendered judgment on the same issue.
Synopsis of Rule of Law.
Under the Rooker Feldman Doctrine, a party may litigate the same issue in state and federal court at the same time, before one court issues a judgment.
Exxon Corp. and Mobil Corp. (Exxon Mobil Corp.) entered into joint ventures with Saudi Basic Industries Corporation (SABIC). A dispute over royalties caused SABIC to sue Exxon Mobil Corp. in Delaware state court, while Exxon Mobil Corp. countersued in federal district court. SABIC moved to dismiss the federal court action, and the district court denied the motion to dismiss. When the Delaware state court issued its final judgment, the circuit court of appeals ruled that the Rooker Feldman Doctrine barred the federal suit.
Whether a party can litigate the same issue in state and federal court at the same time under the Rooker Feldman Doctrine?
No. The United States District Court for the Third Circuit erred in their application of the Rooker Feldman doctrine, because Exxon Mobil Corp. was not seeking an appeal from the state court judgment. Exxon Mobil Corp. in fact filed suit prior to the Delaware state court reaching a verdict. The judgment of the district court is reversed and remanded.
The Rooker Feldman doctrine exists to prevent parties who lose in state court from appealing the decision in federal court, as federal courts have original jurisdiction. The Supreme Court of the United States is the only federal court that may review the decision of a state court.