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The Rook that Would Be King: Rooker-Feldman Abstention Analysis After Saudi Basic

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The Rooker-Feldman doctrine prevents federal district courts from assuming jurisdiction in cases that seek review of state court judgments. For years, the doctrine was applied widely–often barring federal jurisdiction in cases far beyond the scope of the original doctrine. In 2005, the Supreme Court in Saudi Basic intervened to clarify Rooker-Feldman and to curtail its more extravagant applications. Ten years on, this Comment presents an original empirical analysis of the effects of the Saudi Basic decision on Rooker-Feldman analysis in federal district courts. The findings suggest that Rooker-Feldman abstention remains a popular tool for declining federal jurisdiction. Moreover, data suggest that its application has actually proliferated following the Saudi Basic decision, raising questions about the efficacy of the Court’s intervention and the development of procedural doctrine at the Supreme Court.

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