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Carl Michael Seibert v. Jeremy McIntire, et al.

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 20-11931 · judgment May 5, 2021


Certiorari denied · February 22, 2022
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Federal question jurisdiction usually vests in the federal district courts under 28 U.S.C. § 1331. The Rooker-Feldman doctrine represents a narrow exception to this general jurisdiction. In Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 125 S.Ct. 1517 (2005), this Court emphasized that Rooker-Feldman is limited in scope, being “confined to ... cases brought by state-court losers ... inviting district court review and rejection of those judgments.” Id. at 284. Four requirements must be met before this doctrine applies: the federal plaintiff lost in state court; the plaintiff complains of injuries caused by the state-court judgment; the judgments were rendered before the federal suit was filed; and the plaintiff is inviting the district court to review and reject the state judgments. The questions presented by the instant case primarily involve the application of Rooker-Feldman to when a plaintiff brings claims independent of underlying state court judgments, and seeks, not to overturn state court judgments, but monetary damages and declaratory judgments that individual actors involved violated plaintiff’s due process rights. The questions presented are: I. Whether the Eleventh Circuit’s purported “inextricably intertwined” ‘standard’ for evaluating jurisdictional claims under Rooker-Feldman arbitrarily and impermissibly limits district courts’ subject matter jurisdiction and correspondingly, plaintiffs’ ability to obtain access to court for redress of constitutional violations under 42 U.S.C. § 1983, in violation of this Court’s Exxon Mobil rule?

Counsel of record

For petitioner
Douglas Harry Scofield
The Revill Law Firm

For respondent

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Feb 22 2022
    Petition DENIED.
  2. Feb 02 2022
    DISTRIBUTED for Conference of 2/18/2022.
  3. Dec 06 2021
    Petition for a writ of certiorari filed. (Response due January 13, 2022)