Lemon v. Tucker’s Empirical Analysis

Citation profile

2 district · 2 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The Rooker-Feldman doctrine holds that federal appellate review of judgments rendered by state courts can only occur in the Supreme Court, by appeal or by writ of certiorari. [District of Columbia Court of Appeals v.] Feldman, 460 U.S. [462,] 482, 103 S.Ct. [1303,] 1314—15[, 75 L.Ed.2d 206 ]; Rooker [v. Fidelity Trust Co.], 263 U.S. [413,] 416, 44 S.Ct. [149,] 150[, 68 L.Ed. 362 ]. Under this doctrine, a federal district court challenge to the correctness of a state court judgment must be dismissed for lack of subject matter jurisdiction. This doctrine applies even where the federal action seeks to challenge the procedures by which the state court rendered its judgment, so long as the constitutional claims presented to the federal court are “inextricably intertwined” with the merits of the state court judgment. Feldman, 460 U.S. at 483 -84 n. 16, 103 S.Ct. at 1315 n. 16. In such a case, the federal district court is in essence being called upon to review a state court judgment. “This it may not do.” Id.”

   2 later decisions quote this exact passage · from the concurrence
   e.g. 71 F. Supp. 2d 730 - Anderson v. Charter Tp. of Ypsilanti · 102 F. Supp. 2d 772 - Nunnery v. Florida

2. “The central feature to every Younger case is still not present here. The federal plaintiffs in this case are not defendants in the state action. They therefore cannot raise their federal claims by way of defense in the state proceedings. Defendant argues that the plaintiffs here are indeed parties to a state administrative proceeding in which they can obtain all the relief they are seeking here. But that pending administrative proceeding is not an action brought by a state actor against plaintiffs to enforce important state policies. It is brought by the same plaintiffs to this action — private employees who believe they have been discriminated against. True, in that state proceeding the plaintiffs argue not only that they have been discriminated against, but also that the procedures for processing their discrimination claims violate due process. That is the same claim raised here. But unlike every other Younger case, the relationship of the parties to this federal action is not an inversion of their relationship in the related state action. The relationship is the same. This is not a mere technical aberration. It means that the fundamental concern of Younger is absent here. As already explained, the basic principle of Younger is that a federal court should not interfere with a state’s interest in enforcing its own laws when the party defending the state enforcement proceeding can obtain all the relief he desires by raising his federal claim as a state defense. But where, as ”

   1 later decision quote this exact passage · from the concurrence
   e.g. 34 F. Supp. 2d 693 - Cooper v. Bombela

3. “Thus, defendant’s request for abstention is really based on the argument that since the plaintiffs can obtain their desired relief by raising their federal claims as state plaintiffs, this court should remit the plaintiffs to that forum. But, if this court were to abstain in this case merely because the state plaintiffs can raise their federal claims in state administrative proceedings, then the result would essentially be a requirement that a federal plaintiff exhaust his constitutional claims in a state forum before resorting to a federal forum. The Supreme Court in Ohio Civil Rights Commission v. Dayton Christian Schools, Inc., 477 U.S. 619, 106 S.Ct. 2718 , 91 L.Ed.2d 512 (1986), has explicitly held that such a view would be contrary to law.”

   1 later decision quote this exact passage · from the concurrence
   e.g. 34 F. Supp. 2d 693 - Cooper v. Bombela