Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005)
Primary Holding
The Rooker-Feldman doctrine is limited to cases where state-court losers seek to challenge state court judgments in federal court, and it does not extend to other situations that would override preclusion law or allow federal courts to dismiss cases in deference to state court actions.
In the case of Exxon Mobil Corp. v. Saudi Basic Industries Corp., the Supreme Court clarified a legal principle called the Rooker-Feldman doctrine, which limits when people can take state court decisions to federal court. This matters because it protects consumers by ensuring that federal courts can still hear cases that don’t directly challenge state court rulings, allowing for more opportunities to seek justice. If you feel wronged by a decision made in state court but your case involves different issues, this ruling means you might still have a chance to pursue your case in federal court.
AI-generated plain-language summary to help you understand this case
Two subsidiaries of Exxon Mobil planned to produce polyethylene in Saudi Arabia through joint ventures with Saudi Basic Industries Corp. SABIC sued the subsidiaries in state court when they fell into a dispute over the royalties that it had charged them. SABIC sought a declaratory judgment that the royalties were proper, while Exxon Mobil brought a counterclaim in federal court two weeks later on the basis that its subsidiaries had been overcharged by SABIC. Exxon Mobil received a jury verdict in state court of over $400 million, and the federal court denied SABIC's motion to dismiss the claim there. Eight months after the jury verdict in state court, the court of appeals resolved an interlocutory appeal on its own motion by considering whether the Rooker-Feldman doctrine precluded subject-matter jurisdiction over the federal suit, since Exxon Mobil already had the opportunity to litigate its claims in state court. The appeals court eventually ruled that the lower court lost its jurisdiction when the state court entered judgment on the jury verdict, even though the lower court held subject-matter jurisdiction at the outset of the action. This decision created a circuit split over the proper application of the Rooker-Feldman doctrine.
Whether the Rooker-Feldman doctrine applies to bar federal jurisdiction in cases brought by state-court losers seeking to challenge state-court judgments.
The judgment is reversed.
This limitation of a rule that previously had been applied generously reduced the authority of the federal district courts and restored more power to the state courts.
- Court
- Supreme Court
- Decision Date
- February 23, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005)
Consumer LostA federal court in a diversity action may exercise supplemental jurisdiction over additional plaintiffs whose claims do not meet the minimum amount-in-controversy requirement, as long as at least one named plaintiff satisfies that requirement and the claims are part of the same case or controversy.
Lance v. Dennis, 546 U.S. 459 (2006)
Consumer WonThe Rooker-Feldman doctrine does not bar federal jurisdiction over cases brought by state-court losers challenging state-court judgments rendered before the federal proceedings commenced.
Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008)
Consumer LostA shipowner may be liable for punitive damages in maritime law, but such damages should not exceed the amount of compensatory damages awarded.
Powerex Corp. v. Reliant Energy Services, Inc., 551 U.S. 224 (2007)
Consumer LostA foreign corporation that is a wholly owned subsidiary of a foreign state does not qualify as an "organ of a foreign state" under the Foreign Sovereign Immunities Act (FSIA) for the purposes of removal to federal court.