Per Curiam Roundup

Lance v. Dennis

After the Colorado General Assembly redrew the districting lines after winning a seat in the House the Colorado Supreme Court held that the assembly was precluded from redistricting more than once every ten years, and mandated that the state’s court’s redistricting plan be implemented. Two cases arose. The question in this case is whether federal court jurisdiction is barred due to the “Rooker-Feldman” doctrine, which reserves jurisdiction over final state-court judgments to the Supreme Court. This rule denies federal court jurisdiction, requiring “(1) ‘the party against whom the doctrine is invoked must have actually been a party to the prior state-court judgment or have been in privity with such a party’; (2) ‘the claim raised in the federal suit must have actually been raised or inextricably intertwined with the state-court judgment’; and (3) ‘the federal claim must not be parallel to the state-court claim.’”

The District Court held that the citizens (plaintiffs here) fulfilled the first requirement because “the outcome of the government’s litigation over a matter of public concern binds its citizens.” The Court, here, holds that this conclusion conflates Rooker-Feldman with general preclusion rules which would find the parties to be in “privity,” because to hold otherwise would “supplant Congress’ mandate [that] federal courts ‘give the same preclusive effect to state court judgments that those judgments would be given in the courts of the State from which the judgments emerged.”

Justice Stevens dissents, arguing that because the plaintiffs here are, by Colorado state law, clearly in privity with the assembly. Additionally, he argues that Feldman was wrongly decided.

Ministry of Defense and Support for Armed Forces of Islamic Republic of Iran v. Elahi

This case is at the same time boring and complicated, like an international tax case or something. The Court hold that “the Ninth Circuit either mistakenly relied on a concession by respondent that could not possibly bind petitioner, or else erroneously presumed that there was no relevant distinction between a foreign state and its agencies or instrumentalities.” Blugh.

Ash v. Tyson Foods, Inc.

Here, in a Title VII discrimination case, the court holds that A) although it is true that [calling someone, in this case a black man, “boy”] will not always be evidence of racial animus, it does not follow that the term, standing alone, is always benign, and B) the Eleventh Circuit’s standard that the disparity between employment records must be “so apparent as virtually to jump off the page and slap you in the face” in order to establish that the employer’s justification is pretextual is unhelpful and imprecise, and suggests that it may also be too narrow.