Opinion handed down June 19, 2015
Banks v. Slay[1] presents a case that may bring back haunting memories of one’s first-year civil procedure class. The fact pattern in Banks presents a law-exam-worthy catch-all complete with default judgments, writs of mandamus, declaratory judgments, and questions of federal subject matter jurisdiction. All of these issues presented under the guise of police misconduct make for an interesting and noteworthy decision by the U.S. Court of Appeals for the Eighth Circuit.
I. Facts and Holding
In 2002, Michael Banks was allegedly searched and seized by St. Louis police officer Reginald Williams.[2] Banks alleged that Williams had no probable cause for the stop and Williams seized $1100 from Banks that was never included in the police report of the incident.[3] Banks also stated in his complaint that Williams had filed false police reports about Banks leading to a criminal charge for unlawful use of a weapon, a charge of which Banks was later acquitted.[4] Banks’s complaint included other instances of unconstitutional conduct and cited the police board as being deliberately indifferent towards the misconduct.[5]
Both Williams and an attorney for the police board were notified of the pending action against them and the hearing scheduled for the case.[6] However, neither Williams nor anyone representing the police board appeared at the 2009 hearing, and after presenting their evidence of damages, Banks was awarded $900,000 in a default judgment entered against officer Williams “in his personal and official capacities, jointly and severally.”[7]
In 2012, with their default judgment in hand, Plaintiffs petitioned the trial court for a writ of mandamus seeking payment on their default judgment.[8] The state trial court denied Banks’s petition, and Banks appealed.[9] Upon review, the Missouri Court of Appeals for the Eastern District cited authority to either review the trial court’s decision or to review the petition for the writ as if it had been filed in the court of appeals.[10] The court of appeals chose to outright deny Banks’s writ without prejudice, allowing Banks the option to seek an original writ in the Supreme Court of Missouri.[11]
Banks instead chose to bring a declaratory judgment action in the U.S. District Court for the Eastern District of Missouri, against the Mayor of St. Louis, the Treasurer of St. Louis, Comptroller Green, and five members of the police board in their official capacities.[12] The federal district court both denied and abstained deciding on the complaint.[13] The district court found it lacked subject matter jurisdiction and that the case contained an “exceptional” parallel state court proceeding, making it obliged to abstain from rendering a decision.[14]
The case presented here is the appeal from that federal district court decision.
II. Legal Background
The federal district court’s analysis of Banks centered on the Rooker-Feldman doctrine.[15] TheFeldman case stands for the proposition that the Supreme Court of the United States is the only federal court with jurisdiction over appeals from state court judgments.[16] This doctrine was explored thoroughly by the Supreme Court in Exxon Mobil Corp. v. Saudi Basic Industries Corp.[17] In that decision, the Court expanded federal jurisdiction, holding that federal courts do have jurisdiction concurrent with jurisdiction exercised by state courts.[18]
The Rooker-Feldman doctrine is intended only to limit federal jurisdiction in “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.”[19] Thus, a federal district court does not lose subject matter jurisdiction simply because a party attempts to litigate in federal court a matter previously litigated in state court.[20]
Applying the Exxon prodigy to a Missouri case is Edwards v. City of Jonesboro.[21] The plaintiff in Edwards brought a claim against the city of Jonesboro in federal court in an action arising out of a dispute over a landfill that was leaking methane gas onto his land and reducing his property value.[22] The federal district court held it had subject matter jurisdiction over the claim because although the plaintiff had previously brought a state court action on similar facts, the plaintiff’s injury was caused by the leaking methane and not the state court judgment.[23]
III. Instant Decision
The Eighth Circuit looked to the cause of the injury in Banks in rendering its holding. The injury was not the denial of the writ of mandamus by the state trial court, but rather was caused by the Defendant’s refusal to honor the default judgment.[24] Specifically, the court noted that the Plaintiffs did not seek the federal court to “overturn an injurious state-court judgment.”[25] Thus, the Eighth Circuit held that the federal district court erred in its overly-broad application of the Rooker-Feldman doctrine.[26]
As to the abstention by the federal district court, the Eighth Circuit held flatly that this was applied inappropriately in this case.[27] Abstention is only viable when there is a pending action in state court.[28] Here, although Banks had the option to pursue an action with the Supreme Court of Missouri, Plaintiffs had not done so and had not petitioned for mandamus in the state supreme court.[29]
The Eighth Circuit thus reversed the judgment of the district court and remanded for further proceedings.
IV. Comment
This case is a wonderful illustration of the dynamic tension that exists between state and federal judicial systems. One can fully appreciate the federal courts’ worry when faced with this situation. They do not want to infringe upon what, on its face, appears to be an issue wrapped up tightly within the state court system. The Eighth Circuit does a masterful job of parsing out the controlling case law and boiling the issues down to their simplest form. Because the injury was not caused by something the state courts did,[30] and because plaintiffs did not seek a new writ from the Supreme Court of Missouri, there were not obstacles to federal district court jurisdiction.
Apart from the intricacies of federal subject matter jurisdiction, the City of St. Louis may have learned a powerful lesson drawn from a first-year civil procedure lecture. If one is summoned to court, one better show up or have an attorney make a special appearance on ones’ behalf, because a default judgment is a bitter pill to swallow.
- Travis Braun
[1] 789 F.3d 919 (8th Cir. 2015).
[2] Id. at 921. The word “allegedly” is included as the claims raised by Banks and Rush-Banks were never heard in court, but received a default judgment. See infra.
[3] Id.
[4] Id.
[5] Id.
[6] Id.
[7] Id.
[8] Id.
[9] Id.
[10] Id. (citing U.S. Dep’t of Veterans Affairs v. Boresi, 396 S.W.3d 356, 359 n.1, 364 (2013) (Fischer, J., concurring)).
[11] Id.; see Mo. S. Ct. Rule 94.
[12] Banks, 789 F.3d at 921.
[13] Id. at 922.
[14] Id.
[15] Id.
[16] Id.; see District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983).
[17] 544 U.S. 280 (2005).
[18] Banks, 789 F.3d at 922; Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 283 (2005).
[19] Banks, 789 F.3d at 922; Exxon Mobil Corp., 544 U.S. at 284.
[20] Exxon Mobil Corp., 544 U.S. at 284.
[21] 645 F.3d 1014 (8th Cir. 2011).
[22] Id. at 1016-17.
[23] Id. at 1018-19.
[24] Banks, at 923
[25] Id. (citing Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 291-92 (2005)).
[26] Id.
[27] Id.
[28] Id.
[29] Id.
[30] It may be helpful to point out that “choosing not to enforce a default judgment” does not rise to the level of state court induced injury needed to invoke the Rooker-Feldman doctrine.
