Subject-matter jurisdiction; Applicability of 28 USC § 1257(a); Rooker v Fidelity Trust Co; District of Columbia Court of Appeals v Feldman; Exxon Mobil Corp v Saudi Basic Indus Corp; Whether the suit sought district court review & rejection of a state-court judgment

[This appeal was from the ED-MI.] The court held that the Rooker-Feldman doctrine did not apply because plaintiff-HPIL’s suit did not challenge an underlying state-court order appointing a receiver itself, but rather raised issues about wrongdoing in the proceedings. Thus, it reversed the district court’s dismissal of the suit for lack of subject matter jurisdiction under § 1257(a), and remanded. Minority shareholders in HPIL successfully sought the appointment of a receiver in state court, and three years later, HPIL filed this suit alleging that they “looted the corporation during the receivership proceeding.” The district court ruled that it lacked subject-matter jurisdiction under “§ 1257(a), which permits disappointed state litigants to seek review of state-court decisions in the United States Supreme Court but does not permit them to appeal such decisions to a federal district court.” However, the court concluded that Rooker and Feldman only “stand for the straightforward proposition that a lower federal court may not entertain a direct appeal ‘to reverse or modify’ the ‘judgment’ of a state court.” Those cases do “not alter or eliminate the grants of federal-court jurisdiction concurrent with the jurisdiction of state tribunals.” It noted that the Supreme Court has interpreted the doctrine narrowly and repeatedly declined to apply it. The court held that § 1257(a) eliminates “jurisdiction only over ‘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.’” And it concluded that HPIL’s suit did not fit within this category where “[c]hallenges to wrongdoing in the proceedings leading to a judgment do not challenge the judgment itself.” This suit did “not appeal anything or for that matter seek a writ of certiorari over anything.” Rather, it challenged “different wrongs from the previous state-court lawsuits” and it requested “different forms of relief.” Thus, the court found that “neither Rooker nor Feldman nor § 1257 has anything to do with this case.”