In Edwards v. City of Jonesboro, No. 10-2405 (July 14, 2011), the U.S. Court of Appeals for the Eighth Circuit held that a takings claim brought in federal court after the property owner prevailed on the same claim in state court was not barred by the Rooker-Feldman doctrine, but that the state court judgment was final and precluded relitigation of the owner’s federal claims.
Methane gas, released by decomposing waste in the the city’s landfill, invaded adjacent land, rendering it undevelopable, so the owner sued the city. He filed an action in state court; alleging violations of his rights under state law (inverse condemnation, trespass, violations of the state constitution, and the like), and under federal law (takings, etc). With his third amended complaint, however, he filed an England reservation, withholding his federal claims from resolution in state court.
After a trial, the state court ordered the city to pay $400,000 for the value of the land and the property taxes the owner had paid, but did not award prejudgment interest. The property owner did not perfect his appeal, and the Arkansas Supreme Court dismissed it.
The owner then sued in federal court: “[h]e asserted, under 42 U.S.C. § 1983, claims of inverse condemnation, trespass, nuisance,negligence and negligence per se, and strict liability, in violation of his rights under the First, Fifth, and Fourteenth Amendments.” Slip op. at 3. The district court dismissed, concluding that his claims had already been litigated in state court and were thus precluded, or that it lacked subject matter jurisdiction under the Rooker-Feldman doctrine.
The court of appeals held that the Rooker-Feldman doctrine — which prohibits a federal district court from hearing a claim that an injury was caused by a state court judgment — did not apply because the plaintiff’s “claims for inverse condemnation, trespass, nuisance, negligence and negligence per se, and strict liability complain not of injuries caused by the state-court judgment, but of injuries caused by the invasion of [the] land by methane emanating from the City’s landfill.” Slip op. at 5.
But even though it was not barred by Rooker-Feldman, the property owner’s federal lawsuit was barred by the full faith and credit statute (28 U.S.C. § 1738), which requires a federal court to give the same preclusive effect to a state court judgment that state courts would give it. Under Arkansas preclusion law, the plaintiff’s claims would be barred because “[c]laim preclusion bars not only claims that were litigated, but also claims that could have been litigated and that are based on the same events as claims that were litigated.” Slip op. at 7. The plaintiff could have brought his federal claims as part of his state court lawsuit (indeed, before he amended his complaint and reserved his federal claims, he expressly did seek to litigate them in state court).
Edwards v City of Jonesboro, No. 10-2405P (8th Cir. July 15, 2011)