Federación Puertorriqueña de Trabajadores v. Junta de Relaciones, No. 03-1979. This case is interesting for law nerds, some understanding of the facts, for fact nerds is necessary. Federacion the subject of a grievance before the Puerto Rican Labor board. Federacion claimed that the board didn't have jurisdiction as federal law preempted it. The Federacion lost in Puerto Rican courts in interlocutory reivew. Not to be daunted, they then tried their hand in the US District Court.
“The district court concluded that it lacked jurisdiction over the Federación's claim because resolving that claim would require the court to review the decision of the Puerto Rico courts that the Board had jurisdiction over the labor dispute, in contravention of the Rooker-Feldman doctrine.”
The Rooker-Feldman doctrine [requires federal court absention in ]... cases of the kind from which the doctrine acquired its name: 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. Rooker-Feldman does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions.
After Exxon Mobile, the Supreme Court appears to have made it clear that:
...the Rooker-Feldman doctrine now applies only in the "limited circumstances" where "the losing party in state court filed suit in federal court after the state proceedings ended, complaining of an injury caused by the state-court judgment and seeking review and rejection of that judgment." ... The doctrine "does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions."...
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Today, “Consequently, the applicability of the Rooker-Feldman doctrine no longer turns on whether the state court decision was 'final' or preclusive.' Rather, we examine the posture of the case in the state court -- i.e., whether "state proceedings [have] ended," 125 S. Ct. at 1526 -- and the relief sought in the federal court.... what matters is that the state court proceedings have ended with regard to the sole federal issue, namely, whether the Board's jurisdiction is preempted by the NLRA. That jurisdictional question is separate and independent from the merits of the dispute. It logically should be, and has been, decided in advance of a trial on the merits. Moreover, the Puerto Rico Supreme Court has declined to disturb the lower court's decision, thus exhausting the possibility of further review in the Puerto Rico court system.
But, in the end, the First agrees with the Puerto Rican Courts and the US District Court:
As in Rooker and Feldman, here "the losing party in state court filed suit in federal court after the state proceedings ended, complaining of an injury caused by the state-court judgment and seeking review and rejection of that judgment," ... Consequently, the district court lacked jurisdiction to review the state court decision, despite the interlocutory nature of the Puerto Rico courts' decisions.
But, however, there is a confusing sentence, “The Federación's subsequent federal claim seeks a declaration that the Board's jurisdiction was preempted by federal labor law. That claim could succeed only if the federal court were to hold that the Puerto Rico decision was incorrect.” So in, this hypothetical situation, how could the District Court ever reach the merits to conclude that the Puerto Rican decision was incorrect? Maybe I am missing something.
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