explaining the assumption that federal claims 4 Indeed, the Supreme Court has held that “[f]amily relations are a traditional area of state concern.” Moore v. Sims, 442 U.S. 415, 435 (1979). 5 To the contrary, the Minnesota Court of Appeals on numerous occasions has addressed procedural-due-process and judicial-bias claims in domestic relations cases. See, e.g., Haefele v. Haefele, 621 N.W.2d 758, 766 (Minn. Ct. App. 2001). can be raised in a state proceeding unless the plaintiff presents “unambiguous authority to the contrary”
How later courts described this case
- explaining the assumption that federal claims 4 Indeed, the Supreme Court has held that “[f]amily relations are a traditional area of state concern.” Moore v. Sims, 442 U.S. 415, 435 (1979). 5 To the contrary, the Minnesota Court of Appeals on numerous occasions has addressed procedural-due-process and judicial-bias claims in domestic relations cases. See, e.g., Haefele v. Haefele, 621 N.W.2d 758, 766 (Minn. Ct. App. 2001). can be raised in a state proceeding unless the plaintiff presents “unambiguous authority to the contrary”
- holding that while Younger abstention is only justified if the pending state proceeding has the authority to adjudicate a litigant’s federal claims, “when a litigant has not attempted to present his federal claims in related state-court proceedings, a federal court should assume that state procedures will afford an adequate remedy in the absence of unambiguous authority to the contrary.”
- holding that “Younger abstention [is applicable] not only when the pending state proceedings are criminal, but also when certain civil proceedings are pending, if the State’s interests in the proceeding are so important that exercise of the federal judicial power would disregard the comity between the States and the National Government”
- finding that lower court should have abstained from deciding the issue before the court; however, in recognizing the propriety of federal abstention, the Court also implicitly recognized that the Rooker-Feldman doctrine did not bar the district court’s federal jurisdiction to decide those abstention questions
Written by the judges who cited it.
The opinion
Justice Scalia,
with whom Justice O’Connor joins, concurring.
I join the opinion of the Court. I write separately only to indicate that I do not believe that the so-called Rooker-Feldman doctrine deprives the Court of jurisdiction to decide Texaco’s challenge to the constitutionality of the Texas stay and lien provisions. In resolving that challenge, the Court need not decide any issue either actually litigated in the Texas courts or inextricably intertwined with issues so litigated. Under these circumstances, I see no jurisdictional bar to the Court’s decision in this case.