Whether Rooker-Feldman and the Eleventh Amendment jurisdictionally bar a § 1983 challenge to a state procedural rule announced in a state court decision that did not reach the merits of a claim purely based on state law

In state court, Kendrick Simpson raised a single claim based purely on state law. He argued Oklahoma’s execution statute violates the state constitution’s nondelegation doctrine. The state court ruled that his claim was unripe. Under 42 U.S.C. § 1983, Simpson challenged the state procedural process in federal court . The decision below concluded that the court lacked jurisdiction under Rooker -Feldman and the Eleventh Amendment . Three times in the last three years, this Court has granted certiorari to consider jurisdictional issues stemming from § 19 83 challenges to state procedural processes.1 In each case, the Court reversed or vacated a decision from the Fifth Circuit that held jurisdiction was lacking. Despite this Court’s unidirectional movement toward a narrower and potentially nonexistent2 Rooker -Feldman , the decision below invoked a 2021 Fifth Circuit case3 to employ an expansive view of the doctrine. It concluded Simpson is harmed solely by the state court judgment —not by the prison executing him. The decision then folded that faulty causal reasoning into its Ex parte Young analysis. It concluded that the Defendants (the officials executing him) have no connection to Simpson’s injury because they are not responsible for the state judgment. Contrary to the supremacy of federal law, the decision below expand s Rooker -Feldman , narrows Ex parte Young, and immunize s state officials from federal civil rights suits. The question presented is: Whether Rooker -Feldman and the Eleventh Amendment jurisdictionally bar a § 1983 challenge to a state procedur al rule announced in a state court decision that did not reach the merits of a claim purely based on state law . 1 See Reed v. Goertz , 598 U.S. 230, 23435 (2023) ; Gutierrez v. Saenz , 606 U.S. 305, 309 (2025) ; Wood v. Patton , 145 S. Ct. 2839 (June 30, 2025) (GVR in light of Gutierrez ). 2 See Brief for Petitioner at § II, T.M. v. Univ. of Md. Med. Sys. Corp. , No. 25 -197. 3 Rhoades v. Martinez , No. 21 -70007, 2021 WL 4434711 (5th Cir. 2021) . The reasoning of the unpublished decision garnered two votes. One judge concurred in the judgment only. Id . at n*. ii STATEMENT OF RELATED CASES • Underwood v. Harpe , PR -122401 (Okla. Aug. 19, 2024) (Oklahoma Supreme Court transferring state case to the Oklahoma Court of Criminal Appeals) • Underwood v. Harpe , PR -2024637 (Okla. Crim. App. Sept. 17, 2024) (Oklahoma Court of Criminal Appeals holding that the state case was unripe) • Underwood v. Harpe , PR -122536 (Okla. Oct. 21, 2024) (Oklahoma Supreme Court refusing to reconsider the state claim) • Simpson v. Quick, et al. , No. CIV25-1221 -D, 2025 WL 3689156 (W.D. Okla. Dec. 19, 2025) (federal district court dismissing case) • Simpson v. Quick, et al. , No. CIV -25-1221 -D, 2026 WL 66966 (W.D. Okla . Jan. 8, 2026) (federal district court denying a request to enjoin Simpson’s execution pending appeal) • Simpson v. Quick, et al. , No. 266008 , 2026 WL 323320 (10th Cir. Feb. 4, 2026) (federal appeals court affirming district court and dismissing injunction request as moot) • Simpson v. Quick, et al. , No. 266008 , 2026 WL 323320 (10th Cir. Feb. 6, 2026) (federal appeals court denying rehearing en banc)