Background
In 1980, two subsidiaries of Exxon Mobil Corporation (the plaintiff and petitioner in this matter) formed a joint venture with defendant/respondent Saudi Basic Industries Corporation (SABIC). Twenty years later, a dispute arose over royalties SABIC had charged Exxon Mobil's subsidiaries for sublicenses to a polyethylene manufacturing method, and SABIC sued the two subsidiaries in Delaware Superior Court in July 2000.
Instead of first filing a counterclaim in the Delaware state court system, Exxon Mobil and its subsidiaries chose to sue SABIC in the United States District Court for the District of New Jersey. There, they alleged that SABIC had overcharged the subsidiaries for the sublicenses. Exxon Mobil claimed subject-matter jurisdiction in federal court under 28 U.S.C. § 1330, which gives the United States district courts jurisdiction over foreign states.
In January 2002, Exxon Mobil filed an answer to SABIC's complaint in the Delaware state court, asserting the same counterclaims that they had filed in federal court. Meanwhile, SABIC moved to dismiss the federal suit. The district court denied the motion. The state suit reached trial first, and the jury returned a huge verdict for Exxon Mobil, totalling over $400 million. SABIC then appealed the judgment to the Delaware Supreme Court.
SABIC also filed an interlocutory appeal with the United States Court of Appeals for the Third Circuit of the denial of their motion to dismiss the federal suit. The Third Circuit raised, sua sponte (on its own motion), the issue of subject-matter jurisdiction, and concluded that the Rooker-Feldman doctrine precluded the district court from proceeding, on the grounds that Exxon Mobil's claims had already been heard in state court—even though Exxon Mobil was not seeking to have the state court verdict overturned.
Personal jurisdiction is a court's jurisdiction over the parties, as determined by the facts in evidence, which bind the parties to a lawsuit, as opposed to subject-matter jurisdiction, which is jurisdiction over the law involved in the suit. Without personal jurisdiction over a party, a court's rulings or decrees cannot be enforced upon that party, except by comity; i.e., to the extent that the sovereign which has jurisdiction over the party allows the court to enforce them upon that party. A court that has personal jurisdiction has both the authority to rule on the law and facts of a suit and the power to enforce its decision upon a party to the suit. In some cases, territorial jurisdiction may also constrain a court's reach, such as preventing hearing of a case concerning events occurring on foreign territory between two citizens of the home jurisdiction. A similar principle is that of standing or locus standi, which is the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case.
Res judicata (RJ) or res iudicata, also known as claim preclusion, is the Latin term for matter decided and refers to either of two concepts in both civil law and common law legal systems: a case in which there has been a final judgment and that is no longer subject to appeal; and the legal doctrine meant to bar relitigation of a claim between the same parties.
An abstention doctrine is any of several doctrines that a United States court may apply to refuse to hear a case if hearing the case would potentially intrude upon the powers of another court. Such doctrines are usually invoked where lawsuits involving the same issues are brought in two different court systems at the same time.
The Rooker–Feldman doctrine is a doctrine of civil procedure enunciated by the United States Supreme Court in two cases, Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983). The doctrine holds that lower United States federal courts—i.e., federal courts other than the Supreme Court—should not sit in direct review of state court decisions unless Congress has specifically authorized such relief. In short, federal courts below the Supreme Court must not become a court of appeals for state court decisions. The state court appellant has to find a state court remedy, or obtain relief from the U.S. Supreme Court.
Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), was a case in which the United States Supreme Court enunciated a rule of civil procedure that would eventually become known as the Rooker-Feldman doctrine (also named for the later case of District of Columbia Court of Appeals v. Feldman, 460 U.S. 462. The doctrine holds that lower United States federal courts may not sit in direct review of state court decisions.
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), was a case decided by the United States Supreme Court in which the Court enunciated a rule of civil procedure known as the Rooker-Feldman doctrine. The doctrine holds that lower United States federal courts may not sit in direct review of state court decisions.
Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976), was a case in which the Supreme Court of the United States extensively refined the abstention doctrine to prevent duplicative litigation between state and federal courts.
Commodity Futures Trading Commission v. Schor, 478 U.S. 833 (1986), was a case in which the Supreme Court of the United States held an administrative agency may, in some cases, exert jurisdiction over state-law counterclaims.
The Supreme Court of the United States handed down sixteen per curiam opinions during its 2005 term, which lasted from October 3, 2005, until October 1, 2006.
Caterpillar Inc. v. Lewis, 519 U.S. 61 (1996), held that federal jurisdiction predicated on diversity of citizenship can be sustained even if there did not exist complete diversity at the time of removal to federal court, so long as complete diversity exists at the time the district court enters judgment.
Bowoto v. Chevron Corp. was a lawsuit against Chevron Nigeria Ltd., a subsidiary of Chevron USA, which went to trial in 2008 in the United States District Court for the Northern District of California. The plaintiffs, Nigerian citizens who had been injured during or who had survived human rights violations perpetrated by Nigerian military personnel, alleged that the Chevron subsidiary backed the military action and that the parent company thus should bear liability in US courts for the resultant fallout. The suit was decided on December 1, 2008, when nine jurors unanimously agreed Chevron was not liable for any of the numerous allegations. Judgment was entered the next day, officially exonerating Chevron.
Human rights violations in Aceh, Indonesia occurred in the late 1990s and early 2000s when ExxonMobil hired Indonesian military units to guard their Arun gas field, and these military units raided and razed local villages. Government inquiries have extensively documented these abuses. Victims allege that ExxonMobil knew about the atrocities, which include assault, torture, and murder, and should be liable for them. The company denies these accusations; its primary defense is that the human rights violations which were occurring were not a result of specific intention of the organization and therefore it cannot be held liable.
Kivalina v. ExxonMobil Corp., No. 4:08-cv-01138, is a lawsuit filed on February 26, 2008, in a United States district court. The suit, based on the common law theory of nuisance, claims monetary damages from the energy industry for the destruction of Kivalina, Alaska by flooding caused by climate change. The damage estimates made by the U.S. Army Corps of Engineers and the Government Accountability Office are placed between $95 million and $400 million. This lawsuit is an example of greenhouse gas emission liability.
American Electric Power Company v. Connecticut, 564 U.S. 410 (2011), was a United States Supreme Court case in which the Court, in an 8–0 decision, held that corporations cannot be sued for greenhouse gas emissions (GHGs) under federal common law, primarily because the Clean Air Act (CAA) delegates the management of carbon dioxide and other GHG emissions to the Environmental Protection Agency (EPA). Brought to court in July 2004 in the Southern District of New York, this was the first global warming case based on a public nuisance claim.
Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005), was a case in which the Supreme Court of the United States held that 28 U.S.C. § 1367 permits supplemental jurisdiction over joined claims that do not individually meet the amount-in-controversy requirements of § 1332, provided that at least one claim meets the amount-in-controversy requirements.
John Doe VII v. Exxon Mobil Corp (09–7125) is a lawsuit filed in the United States by 11 Indonesian villagers against ExxonMobil Corporation alleging that the company is responsible for human rights violations in the oil-rich province of Aceh, Indonesia. The case has broad implications for multinational corporations doing business in other countries. Indonesian security forces committed torture, rape, and murder against the plaintiffs and their families while under contract with ExxonMobil to guard the Arun gas field during the late 1990s and early 2000s; plaintiffs claim that Exxon is responsible for these atrocities.
Stern v. Marshall, 564 U.S. 462 (2011), was a United States Supreme Court case in which the Court held that a bankruptcy court, as a non-Article III court lacked constitutional authority under Article III of the United States Constitution to enter a final judgment on a state law counterclaim that is not resolved in the process of ruling on a creditor's proof of claim, even though Congress purported to grant such statutory authority under 28 U.S.C. § 157(b)2(C). The case drew an unusual amount of interest because the petitioner was the estate of former Playboy Playmate and celebrity Anna Nicole Smith. Smith died in 2007, before the Court decided the case, which her estate lost.
Reed Elsevier, Inc. v. Muchnick, 559 U.S. 154 (2010), was a decision by the Supreme Court of the United States involving copyright law. The Court held that failure to register a copyright under Section 411 (a) of the United States Copyright Act does not limit a Federal Court's jurisdiction over claims of infringement regarding unregistered works.
The Anti-Injunction Act, is a United States federal statute that restricts a federal court's authority to issue an injunction against ongoing state court proceedings, subject to three enumerated exceptions. It states:
Chick Kam Choo v. Exxon Corp., 486 U.S. 140 (1988), was a United States Supreme Court case in which the Court held that a federal court's dismissal of a civil action on the ground that it should be heard in a foreign court, under the doctrine of forum non conveniens, does not preclude the plaintiff from filing the same action in a state court that applies different forum non conveniens rules.
