Exxon Mobil Corp. v. Saudi Basic Industries Corp.
| Exxon Mobil Corp. v. Saudi Basic Industries Corp. | |
|---|---|
 | |
| Argued February 23, 2005 Decided March 30, 2005 | |
| Full case name | Exxon Mobil Corporation, Exxon Chemical Arabia, Inc., and Mobil Yanbu Petrochemical Company, Inc., Petitioners v. Saudi Basic Industries Corporation |
| Citations | 544U.S.280(more) 125 S. Ct. 1517; 161L. Ed. 2d454; 2005U.S. LEXIS2929; 73 U.S.L.W. 4266; 18 Fla. L. Weekly Fed. S 206 |
| Case history | |
| Prior | On writ of certiorari to theUnited States Court of Appeals for the Third Circuit,Exxon Mobil Corp. v. Saudi Basic Indus. Corp.,364F.3d102, 2004 U.S. App. LEXIS 5485 (3d Cir. 2004) |
| Holding | |
| The Rooker-Feldman doctrine applies only where a federal court litigant seeks to review or overturn state court judgments in federal district court. Third Circuit decision reversed. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Ginsburg, joined byunanimous |
| Laws applied | |
| 28 U.S.C.§ 1257 | |
Exxon Mobil Corp. v. Saudi Basic Industries Corp.,544 U.S. 280 (2005), is aUnited States Supreme Courtcase in which the Court clarified theRooker-Feldman doctrineand its relation to preclusion andconcurrent jurisdiction.
Background[edit]
In 1980, two subsidiaries ofExxon Mobil Corporation(theplaintiffand petitioner in this matter) formed ajoint venturewithdefendant/respondentSaudi Basic Industries Corporation(SABIC). Twenty years later, a dispute arose overroyaltiesSABIC had charged Exxon Mobil'ssubsidiariesforsublicensesto apolyethylenemanufacturing method, and SABIC sued the two subsidiaries inDelaware Superior Courtin July 2000.
Instead of first filing acounterclaimin theDelawarestate court system, Exxon Mobil and its subsidiaries chose to sue SABIC in theUnited States District Court for the District of New Jersey.There, they alleged that SABIC had overcharged the subsidiaries for the sublicenses. Exxon Mobil claimedsubject-matter jurisdictionin federal court under28 U.S.C.§ 1330,which gives theUnited States district courtsjurisdiction over foreign states.
In January 2002, Exxon Mobil filed an answer to SABIC's complaint in the Delaware state court, asserting the same counterclaims that they had filed in federal court. Meanwhile, SABICmovedtodismissthe federal suit. The district court denied the motion. The state suit reached trial first, and the jury returned a huge verdict for Exxon Mobil, totalling over $400 million. SABIC then appealed the judgment to theDelaware Supreme Court.
SABIC also filed aninterlocutory appealwith theUnited States Court of Appeals for the Third Circuitof the denial of their motion to dismiss the federal suit. The Third Circuit raised,sua sponte(on its own motion), the issue ofsubject-matter jurisdiction,and concluded that the Rooker-Feldman doctrine precluded the district court from proceeding, on the grounds that Exxon Mobil's claims had already been heard in state court—even though Exxon Mobil was not seeking to have the state court verdict overturned.
Issue[edit]
The main issue in this case was whether theRooker-Feldman doctrineoverrides thepreclusion doctrine(seeres judicata) orconcurrent jurisdictionof the state & federal courts.
Opinion of the Court[edit]
Justice Ginsburg,writing for a unanimous Court, reversed the Third Circuit's decision and remanded the case. She began her decision with a fairly concise retelling of the holdings in both theRookerandFeldmancases. She then held that the Rooker-Feldman doctrine
is confined to cases of the kind from which the doctrine acquired its name: 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. Rooker-Feldman does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions.
125 S.Ct. at 1521-1522.
This essentially had the effect of cabining the Rooker-Feldman doctrine and limiting its application, defining it as separate and distinct from both preclusion andabstention doctrine.Furthermore, Ginsburg went on to explain that parallel litigation in both state and federal courts does not automatically trigger Rooker-Feldman, and that federal courts must give state court judgments preclusive effect under theFull Faith and Credit Act,28 U.S.C.§ 1738.
External links[edit]
- Text ofExxon Mobil Corp. v. Saudi Basic Industries Corp.,544U.S.280 (2005) is available from:FindlawGoogle ScholarJustiaOyez (oral argument audio)
