Nolan Espinda, Director, Hawaii Department of Public Safety, et al. v. Royce C. Gouveia

This case presents clear and intractable conflicts regarding: 1) the Rooker–Feldman doctrine and the limitations it imposes on the jurisdiction of lower federal courts; 2) Hawai‘i’s sovereign right to enforce its criminal laws; and 3) the appellate deference that the Court has historically accorded to a trial court’s mistrial declaration. [1] The Rooker–Feldman doctrine reflects the principle set forth in 28 U.S.C. § 1257 that the Court is the only federal court that has jurisdiction to review statecourt judgments. Exxon Mobil Corp. v. Saudi Basic Indus. Corp. identified the “paradigm situation” in which the doctrine precludes a federal district court from proceeding as “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Id. 544 U.S. 280, 284, 293 (2005). The first question presented is: Did the Ninth Circuit err in concluding – in direct conflict with the Court’s holding in Exxon – that the Rooker–Feldman doctrine is categorically not applicable to § 2241 petitions including those in which state-court losers invite district court review and rejection of allegedly injurious state-court judgments rendered before the district court proceedings commenced and pursuant to which the state-court losers are not in custody?