No. 24-470

Michelle R. Gilbank v. Wood County Department of Human Services, et al.

Lower Court: Seventh Circuit
Docketed: 2024-10-28
Status: Denied
Type: Paid
Amici (3)
Tags: appellate-jurisdiction circuit-split federal-claims rooker-feldman-doctrine state-judgments subject-matter-jurisdiction
Key Terms:
AdministrativeLaw SocialSecurity DueProcess CriminalProcedure JusticiabilityDoctri
Latest Conference: 2025-02-21
Question Presented (AI Summary)

Should the Rooker-Feldman doctrine extend to bar federal claims for damages where the state judgment neither awarded nor denied damages, meaning the federal claim could not vacate or modify the judgment's relief?

Question Presented (OCR Extract)

QUESTION PRESENTED Deployed in “tens of thousands of circuit and district court decisions,” App.15a, the Rooker-Feldman doctrine stops lower federal courts from exercising appellate jurisdiction over state judgments. Along with other elements required for the doctrine to apply, claims are barred if they invite “district court review and rejection” of a state judgment. Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). The circuits have split over the meaning of “review and rejection.” Some circuits read “review and rejection” broadly to mean disagreement, thus extending Rooker-Feldman to bar federal claims for damages even where the state judgment neither awarded nor denied damages—meaning the federal claim could never vacate or modify the state judgment’s relief. Other circuits read “review and rejection” narrowly, properly limiting Rooker-Feldman to bar federal claims seeking appellate relief that would vacate or modify the state judgment. A fractured en banc Seventh Circuit divided along the existing split. Despite disagreeing on substance, “{a]ll members of the en banc court agree[d]” there is “a need for the Supreme Court to clarify application of the doctrine.” App.3a. The question presented is: Should the Rooker-Feldman doctrine—which stops lower federal courts from exercising appellate jurisdiction over state judgments—extend to bar federal claims for damages where the state judgment neither awarded nor denied damages, meaning the federal claim could not vacate or modify the judgment’s relief?

Docket Entries

2025-02-24
Petition DENIED.
2025-01-22
DISTRIBUTED for Conference of 2/21/2025.
2025-01-17
Reply of Michelle Gilbank submitted.
2025-01-17
2025-01-06
Brief of Wood County Department of Human Services, Theresa Heinzen-Janz, Mary Christensen, Anne La Chapelle, and Mary Solheim in opposition submitted.
2025-01-06
Brief of respondents Wood County Department of Human Services, et al. in opposition filed.
2024-11-27
2024-11-27
2024-11-26
2024-11-13
Motion to extend the time to file a response is granted and the time is extended to and including January 6, 2025, for all respondents.
2024-11-12
Motion of Marshfield Police Department and Derek Iverson for an extension of time submitted.
2024-11-12
Motion to extend the time to file a response from November 27, 2024 to January 6, 2025, submitted to The Clerk.
2024-10-23
Petition for a writ of certiorari filed. (Response due November 27, 2024)

Attorneys

Cato Institute
Caleb Raymond GerbitzMeissner Tierney Fisher & Nichols S.C., Amicus
Law Professors Adam Steinman, Susan Bandes, Edward L. Baskauskas, Jack M. Beermann, Williamson Chang, Heather Elliott, Luke Norris, Thomas D. Rowe, Suzanna Sherry, and Howard M. Wasserman
Conor Denali TuckerSteptoe LLP, Amicus
Marshfield Police Department and Derek Iverson
Jason Raymond JustAmundsen Davis, LLC, Respondent
Michelle Gilbank
Joseph S. DiedrichHusch Blackwell LLP, Petitioner
National Association of Parents, Inc. dba ParentsUSA
David Stanley DeLugasNational Association of Parents, Inc., Amicus
Wood County Department of Human Services, Theresa Heinzen-Janz, Mary Christensen, Anne La Chapelle, and Mary Solheim
Aneet KaurAxley Brynelson LLP, Respondent