Perhaps you have been wondering: “Did Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005), implicitly overrule Hale v. Harney, 786 F.2d 688 (5th Cir. 1986), and thereby limit the scope of the Rooker-Feldman doctrine in the Fifth Circuit?”
If so, you need fret no longer. While the Rooker-Feldman doctrine continues to “generally preclude lower federal courts ‘from exercising appellate jurisdiction over final state-court judgments,” we now know with certainty, from Miller v. Dunn, that “Rooker-Feldman is inapplicable where a state appeal is pending when the federal suit is filing.” No. 20-11054 (June 2, 2022).