Sunday, November 24, 2013

Exxon Mobil Corp. v. Saudi Basic Indus. Corp. case brief

Exxon Mobil Corp. v. Saudi Basic Indus. Corp. case brief summary
544 U.S. 280 (2005)

After respondent foreign company sued petitioner oil company in state court, the oil company sued the foreign company in federal court, alleging that the foreign company overcharged the parties' joint ventures for sublicenses. Certiorari was granted to determine whether the United States Court of Appeals for the Third Circuit erred in ordering the federal action dismissed for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine.


  • The oil company plainly had not repaired to federal court to undo the state court judgment that was ultimately entered in its favor. 
  • Rather, it appeared that the oil company filed suit in federal district court (only two weeks after the foreign company filed in Delaware and well before any judgment in state court) to protect itself in the event it lost in state court on grounds (such as the state statute of limitations) that might not have precluded relief in the federal venue. 
  • The Rooker-Feldman doctrine did not prevent the district court from exercising jurisdiction when the oil company filed the federal action because the pendency of an action in the state court was no bar to proceedings concerning the same matter in a federal court having jurisdiction. 
  • Moreover, the doctrine did not emerge to vanquish jurisdiction after the oil company prevailed in the Delaware courts because disposition of the federal action, once the state-court adjudication was complete, would be governed by preclusion law and preclusion was not a jurisdictional matter. 
  • Thus, the lower court erred in concluding that the Rooker-Feldman doctrine precluded exercise of its federal subject-matter jurisdiction.
The judgment was reversed and the case was remanded for further proceedings.

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