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Friends of the Lakeview School Dist. Incorporation No. 25 of Phillips County v. Huckabee

October 11, 2007

FRIENDS OF THE LAKEVIEW SCHOOL DISTRICT INCORPORATION NO. 25 OF PHILLIPS COUNTY, ET AL. PLAINTIFFS
v.
MIKE HUCKABEE IN HIS OFFICIAL CAPACITY AS GOVERNOR OF THE STATE OF ARKANSAS, ET AL. DEFENDANTS



The opinion of the court was delivered by: Wm. R. Wilson, Jr. United States District Judge

ORDER

Pending are Plaintiffs' Motions for a Ruling*fn1 and a Hearing.*fn2 In response, Defendants filed a Motion to Renew their Motion to Dismiss.*fn3 Plaintiffs did not respond to Defendants' motion.

This is an action for injunctive relief based on alleged violations of 42 U.S.C. § 1983, and the Arkansas Constitution in connection with consolidation of the Lake View School District.*fn4

I. Background

This action was initiated in 2004, and was administratively terminated*fn5 in September 2005, pending the conclusion of similar proceedings before the Arkansas Supreme Court.*fn6 The dismissal order stated that the Court was abstaining from further action, but was retaining jurisdiction. Plaintiffs were given 30 days to reopen the case once the state proceedings were final.*fn7

At the time the case was dismissed, Defendants' Motion to Dismiss*fn8 was pending. This motion alleged that (1) Plaintiffs' claims are not justiciable, and (2) are barred by sovereign immunity, res judicata, and the Rooker-Feldman Doctrine. Plaintiffs had filed a response.*fn9

No further action was taken on the case until Plaintiffs filed a Motion to Reopen in January 2006.*fn10 The motion was denied*fn11 because the Arkansas Supreme Court had not issued a final mandate.*fn12

The Arkansas Supreme Court issued its final decision in May 2007.*fn13 Within 30 days, Plaintiffs filed a Motion for a Ruling,*fn14 which is interpreted as a motion to reopen the case. This motion alludes to an amended complaint,*fn15 but, a proposed amended complaint is not attached as an exhibit.*fn16 Defendants counter that, before any further action is taken, the motion to dismiss should be decided. I agree.

II. Authority

Defendants' motion challenges jurisdiction based on the Rooker-Feldman Doctrine. Jurisdiction is the power to hear an action, consider its merits, and render a binding decision.*fn17 The question of jurisdiction may be raised sua sponte at any time,*fn18 and lack of subject-matter jurisdiction cannot be waived by the parties or ignored by the court.*fn19

Under the Rooker-Feldman Doctrine,*fn20 a party that lost in state court is barred from seeking review of the state judgment in a United States district court, based on the losing party's claim that the state judgment violates the loser's federal rights.*fn21 Federal jurisdiction to review state-court judgments is reserved to the United States Supreme Court.*fn22

Claims decided by the state court and claims that are inextricably intertwined with a state-court decision are barred under Rooker-Feldman.*fn23 A claim is inextricably intertwined if:

(1) the claim's success depends on a finding that the state court was wrong, or (2) a favorable decision would effectively reverse the state court decision or void its ruling.*fn24

Generally, the Rooker-Feldman Doctrine is confined to cases brought by state-court losers complaining about judgments that were rendered before a district court proceedings began.*fn25 The U.S. Supreme Court made it clear that, when state and federal actions are pending simultaneously, Rooker-Feldman is not automatically triggered by a state-court judgment. This is true because properly invoked concurrent jurisdiction does not disappear if a state court reaches judgment on the same or related claim ...


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