Carla Young v. Brian Lundstrom, et al.
Arbitration ERISA Privacy
Whether receiving benefits pursuant to a state-court judgment is an independent claim or an injury caused by a state-court judgment
QUESTIONS PRESENTED In Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005), this Court recognized the departure lower courts had taken from this Court’s precedent in applying the Rooker-Feldman abstention doctrine. Even after Exxon, however, lower courts’ holdings continue to conflict with one another and this Court, including discrepancies of whether an injury is caused by a state-court judgment, whether a plaintiff’s requested relief is seeking review and rejection ofa state-court judgment, and how the “inextricably intertwined” analysis applies. The Ninth Circuit below held that, although a direct, explicit attack of a state-court judgment is barred, relief to enjoin the effects of that judgment is not. The questions presented are: 1. Whether receiving benefits pursuant to a state-court judgment is an independent claim and not an injury caused by a state-court judgment, as the Ninth Circuit held here; or it is an injury caused by the state-court judgment, or in other words, the state-court judgment is the source of that injury such that the claim falls under Rooker-Feldman, as the Second, Sixth, and Tenth Circuits hold, and as the Ninth Circuit has previously held. 2. Whether injunctive relief must “expressly” seek relief from the state-court judgment to fall under Rooker-Feldman, as the Ninth Circuit held here and with which the Fourth, Seventh, and Tenth Circuits somewhat agree; or injunctive relief that can be granted only if the state-court judgment is invalid or ii QUESTIONS PRESENTED—Continued would effectively be nullified by the district court’s action is an invitation to review and reject the state-court judgment, or is inextricably intertwined with the validity of the state-court judgment, such that the claim falls under Rooker-Feldman, as the Third, Eighth, and Eleventh Circuits hold and other Seventh and Tenth Circuit cases have held.