LANCE v. DENNIS
When the Colorado legislature failed to pass a redistricting plan in 2000, the state courts created one at the request of a group of voters. The legislature succeeded in passing a redistricting plan in 2003. The state attorney general brought suit in the Colorado State Supreme Court to require the secretary of state to use the court-ordered plan, and the Colorado General Assembly defended its own plan. The Colorado Supreme Court ruled that the legislature's plan violated Article V of the State Constitution. A group of citizens including Keith Lance brought another suit in federal court alleging that Article V of the Colorado Constitution, as interpreted by the Colorado Supreme Court, violated the Elections Clause of the U.S. Constitution. Under the Supreme Court's Rooker-Feldman doctrine, no federal court except the Supreme Court may hear appeals from state courts. The District Court held that since Lance was in privity with the General Assembly - that is, their claims were similar enough to constitute a mutual interest - Lance's suit was in effect an appeal of the General Assembly's loss in state court. Therefore, the District Court ruled that it had no jurisdiction under the Rooker-Feldman doctrine and declined to hear the case.
Does the Rooker-Feldman doctrine preclude plaintiffs from bringing suit in federal court when they are in privity with a party that lost in state court?
No. In an anonymous 8-1 decision, the Court reversed the District Court. The Court held that "The Rooker-Feldman doctrine does not bar actions by nonparties to the earlier state-court judgment simply because [...] they could be considered in privity with a party to the judgment." Since Lance was not a party to the state-court suit, and was in no position to appeal the Colorado Supreme Court's decision, the District Court had jurisdiction to hear the case. Justice John Paul Stevens wrote a lone dissent expressing a desire to address the validity of the claims brought by Lance's suit.