Is there sufficient disarray in post-Exxon Rooker-Feldman jurisprudence to warrant clarification?

QUESTIONS PRESENTED Petitioner Kleidman requests that this petition be liberally construed. Erickson v. Pardus, 551 US 89, 94 (2007). ; This petition pertains: to the Rooker-Feldman doctrine, named after Rooker v: Fidelity Trust Co., : * 263 US 413 (1923) (Rooker)' and DC Ct. of Appeals : v. Feldman, 460 US 462 (1983). The gist of Rooker. ; Feldman is that one cannot appeal a state-court decision by way of an original action in federal . district court. The Courts of Appeals have cited Rooker-Feldman thousands of times, and yet there ’ is currently substantial disarray, including interand intra-Circuit conflict on numerous aspects of oO Rooker-Feldman, along with disagreements among ; : circuit judges as expressed in numerous : : dissenting and/or concurring opinions. . . Exxon Mobil Corp. v. Saudi Basic Indus. Corp., . . .544 US 280 (2005) made two rulings that will be used in these Questions. First, Rooker-Feldman ... is confined to cases ... : brought by: state-court losers complaining of injuries caused by _ state-court judgments... Id., 284. Second, in a federal-question action (such as here), . : “Rooker-Feldman ... merely recognizes that.28 USC § 1331 is a grant of original : jurisdiction, ... not... appellate jurisdiction over state-court judgments.” : Exxon, 292. . ; : * This method of abbreviating cases (e.g., “Rooker’) is used ; throughout without further mention. , ; il Question 1. Is there sufficient overall disarray in post-Exxon Rooker-Feldman jurisprudence, including interand intra-Circuit conflicts and disharmony, and disagreements among Circuit judges as expressed in dissenting and/or concurring opinions, to warrant this Court’s attention to clarify the scope and contours of ’ Rooker-Feldman? Background to Questions 2a, 2b, 2c. To invoke federal jurisdiction, a federal plaintiff must plead injury in fact, ie., “suffer[ring] the ‘invasion of a legally protected interest.” Gill v. Whitford, 138 S.Ct. 1916, 1920 (2018). ; Question 2a. When a federal plaintiff alleges merely an “injur[y] caused by [a] ... judgment{]” (in the sense of Exxon, 284), does the plaintiff therefore fail to plead injury in fact (since one has no legally-protected interest in having a favorable decision)? Question 2b. Is Rooker-Feldman subsumed under injury-in-fact jurisprudence, and therefore superfluous? Question 2c. Should this Court formally abolish Rooker-Feldman altogether (since resolution of the injury-in-fact inquiry necessarily resolves the Rooker-Feldman inquiry)? Background to Questions 3a-3f. ; In Feldman, Feldman’s petition to the State Court? was denied. In the federal case, Feldman’s fifth cause of action (“Feldman’s Count 5”) alleged that the State Court unconstitutionally discriminated against him by refusing to consider his ? See 28 USC § 1257(b). . lll. . qualifications set forth in his petition (whereas it had presumably considered the qualifications of other, similarly-situated persons). Feldman, 469, ; n. 3. Feldman barred Feldman’s Count 5 because it ; sought impermissible appellate review of the ; State-Court decision. Id., 486-487. . Question 3a. Did Feldman wrongly decide . Feldman’s Count 5? ; Question 3b. In Feldman’s Count 5, was ; Feldman’s alleged injury caused by the StateCourt decision, or was Feldman’s alleged injury the denial of his constitutional rights, caused by OO the State Court’s discriminatory refusal to : consider Feldman’s qualifications? ; Question 3c. If the injury alleged in Feldman’s | ; : Count 5 was the unconstitutional, discriminatory ; . refusal to consider Feldman’s qualifications (not ; ; oc , the State-Court decision), was Feldman’s : treatment of Feldman’s Count 5 erroneous in light . of Exxon? ; ‘Question 3d. Did Feldman’s discussion of ; Feldman’s Count 5 misstate Feldman’s Count 5 by : : asserting, “[Feldman] alleg[ed] that the [State : Court] ... acted’... discriminatorily in denying ; [Feldman’s] .petition{],” when in actuality Feldman : alleged: that the State Court acted d