Jurisdiction Must Be Pleaded—and Jurisdictional Dismissals Must Be Without Prejudice
Introduction
In Sungsuk Kim v. Unlimited Settlement Services (3d Cir. Apr. 16, 2026) (not precedential),
the Third Circuit reviewed the dismissal of a sprawling, 1327-page pro se federal filing arising out of
years of Pennsylvania state-court litigation concerning a mortgage foreclosure, a 2017 fire loss,
insurance proceeds, a settlement involving sale of the property, and subsequent collateral suits.
The appellant, Sungsuk Kim, named 11 defendants spanning multiple groups: settlement-service actors,
insurer and counsel, mortgage servicers and counsel, a neighbor (alleged tortfeasor) and his insurer/counsel,
and a former attorney of Kim’s. The central federal-court problem, however, was not the merits of these
disputes but the absence of a properly pleaded basis for federal subject-matter jurisdiction.
The key issues on appeal were: (1) whether the District Court correctly dismissed the complaint on
Rooker-Feldman grounds; (2) whether dismissal was required because Kim did not allege any basis
for federal jurisdiction; and (3) whether the dismissal could be “with prejudice.”
Summary of the Opinion
The Third Circuit affirmed dismissal but on a different jurisdictional ground than the District Court relied upon.
While the District Court dismissed “with prejudice” based on the Rooker-Feldman doctrine, the Third Circuit held
the complaint should be dismissed because Kim failed to invoke federal jurisdiction at all (i.e., she did not satisfy
Rule 8(a)(1)’s requirement to plead the grounds for subject-matter jurisdiction).
Critically, the Third Circuit modified the judgment to reflect that the dismissal is without prejudice,
because dismissals for lack of jurisdiction cannot adjudicate the merits. The Court also affirmed the refusal to appoint
counsel because Kim did not show a potentially meritorious claim within federal jurisdiction.
Analysis
Precedents Cited
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Lincoln Benefit Life Co. v. AEI Life, LLC, 800 F.3d 99 (3d Cir. 2015)
Cited for the proposition that diversity jurisdiction requires allegations regarding the parties’ citizenship.
The panel used it to underscore the pleading deficiency: Kim did not allege defendants’ citizenship and left
jurisdictional portions of a form complaint blank. Even if she claimed Kansas citizenship, that alone did not
establish complete diversity.
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In re Adams, 151 F.4th 144 (3d Cir. 2025)
Provided the modern Third Circuit framework for applying Rooker-Feldman, including the distinction between
claims that seek appellate-like review of state judgments (potentially barred by Rooker-Feldman) and claims that
merely overlap factually with state litigation (typically governed by preclusion principles).
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Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005)
Central to narrowing Rooker-Feldman. The opinion used Exxon Mobil to emphasize that Rooker-Feldman
does not substitute for ordinary preclusion law and does not apply simply because state and federal matters overlap.
The Court also invoked Exxon Mobil to justify resolving the appeal on a more basic threshold point:
the plaintiff never invoked federal jurisdiction in the first place.
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Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010)
Reinforced that many post-state-court disputes—especially those alleging misconduct by lawyers/parties during state
litigation—are ordinarily analyzed under preclusion doctrines rather than Rooker-Feldman. The panel used this
to suggest the District Court’s “all claims are barred” approach was overbroad.
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In re Knapper, 407 F.3d 573 (3d Cir. 2005)
Referenced as part of the District Court’s reasoning on “inextricably intertwined.” The Third Circuit noted that
current doctrine focuses on whether the federal claim invites review of a final state-court decision, not on an
expansive “intertwined” test divorced from that inquiry.
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In re Johnson & Johnson Talcum Powder Prods. Mktg., Sales Pracs. & Liab. Litig., 903 F.3d 278 (3d Cir. 2018)
Quoted for the presumption against federal jurisdiction: federal courts “presume” jurisdiction is lacking unless it
affirmatively appears in the record. This framed the burden on Kim to plead jurisdiction and supported dismissal
under Rule 8(a)(1).
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Aldossari ex rel. Aldossari v. Ripp, 49 F.4th 236 (3d Cir. 2022)
Supplied the key rule that a plaintiff bears the burden of alleging a legal basis for federal jurisdiction; failure
to do so requires dismissal. The panel also used Aldossari to support declining remand for yet another attempt
given Kim had already been warned and still did not allege jurisdiction.
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Cook v. GameStop, Inc., 148 F.4th 153 (3d Cir. 2025)
The linchpin for the remedial modification: dismissal for lack of subject-matter jurisdiction must be
without prejudice to the merits. This is the opinion’s most concrete “rule of decision” effect: even when
dismissal is proper, “with prejudice” is the wrong disposition when jurisdiction is absent.
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Tabron v. Grace, 6 F.3d 147 (3d Cir. 1993)
Cited for the standard governing appointment of counsel in civil cases. The panel affirmed denial of counsel because
Kim did not show a potentially meritorious claim over which the federal court might have jurisdiction—an implicit
reminder that jurisdictional plausibility is a predicate to discretionary counsel appointment.
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Behrens v. JPMorgan Chase Bank, N.A., 96 F.4th 202 (2d Cir. 2024);
Hartig Drug Co. v. Senju Pharm. Co., 836 F.3d 261 (3d Cir. 2016);
Potter v. Cozen & O'Connor, 46 F.4th 148 (3d Cir. 2022);
Guerra v. Consol. Rail Corp., 936 F.3d 124 (3d Cir. 2019)
These cases addressed an appellate nuance: whether a party can forfeit arguments about jurisdictional labels and the
court’s independent obligation to police subject-matter jurisdiction. While the panel noted the issue, it did not
decide it because dismissal was warranted on the more fundamental ground that jurisdiction had never been pleaded.
Legal Reasoning
The Third Circuit’s reasoning proceeded in three steps:
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Appellate posture and forfeiture: The Court observed Kim did not meaningfully challenge the District
Court’s dismissal rationale and appeared to concede the federal filing was “incorrect.” Although the panel discussed
waiver/forfeiture complexities in jurisdictional contexts, it ultimately resolved the case on an independent
jurisdictional ground.
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Rooker-Feldman was not the best analytic fit for the entire complaint: The panel indicated that
Rooker-Feldman can apply insofar as a plaintiff explicitly seeks review of state-court judgments, but that
reasserted claims or new claims related to the same underlying events are typically handled through preclusion, not
Rooker-Feldman. The District Court’s reliance on “inextricably intertwined” reasoning risked overextension.
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Threshold defect—failure to invoke federal jurisdiction: Independently of Rooker-Feldman, Kim
did not allege any basis for federal jurisdiction as required by Rule 8(a)(1). The panel emphasized that federal
jurisdiction is presumed absent and the burden rests on the party invoking it. The Court found no reason to remand
because Kim had been explicitly instructed in a prior federal case to plead jurisdiction and still left the relevant
portions blank, and she did not respond to jurisdictional arguments raised in a motion to dismiss.
Having affirmed dismissal for lack of subject-matter jurisdiction, the Third Circuit corrected the form of the judgment:
a jurisdictional dismissal cannot be “with prejudice” because it does not reach the merits. Thus, the panel modified
the dismissal to be without prejudice.
Impact
Although designated “not precedential,” the decision is a clear, practice-oriented reminder of several points likely to
influence how district courts and litigants handle similar filings:
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Rule 8(a)(1) is not optional: Even voluminous submissions and detailed factual histories do not
substitute for pleading a concrete jurisdictional basis (federal question or diversity with complete diversity and
appropriate allegations).
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Courts may (and should) resolve on the simplest jurisdictional ground: Rather than over-litigating
Rooker-Feldman, courts can dismiss where jurisdiction is not invoked at all.
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Rooker-Feldman remains narrow: The opinion reinforces the post-Exxon Mobil approach:
preclusion, not Rooker-Feldman, often supplies the correct analysis for claims adjacent to state litigation.
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Disposition matters: “without prejudice” is mandatory for jurisdictional dismissals: The modification
grounded in Cook v. GameStop, Inc. is the opinion’s most concrete doctrinal takeaway and affects judgment
drafting and litigants’ future options (even if practical barriers like preclusion or filing restrictions may remain).
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Counsel appointment depends on jurisdictionally viable merit: Under Tabron v. Grace, a court is
not expected to appoint counsel where the pleadings do not even establish a potentially meritorious claim within the
court’s power to hear.
Complex Concepts Simplified
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Subject-matter jurisdiction: The federal court’s legal authority to hear a type of dispute. If it is
missing, the court must dismiss, no matter how compelling the facts may be.
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Rule 8(a)(1): Requires a complaint to include “a short and plain statement of the grounds for the
court’s jurisdiction.” A plaintiff must identify a federal statute/constitutional basis (federal question) or plead
complete diversity of citizenship and the amount in controversy (diversity).
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Rooker-Feldman doctrine: A narrow rule preventing lower federal courts from acting as appellate courts
over state-court judgments. It does not automatically bar all federal litigation related to a state-court dispute.
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Preclusion (claim/issue preclusion): Rules that can bar re-litigation of claims or issues already
resolved (or that should have been raised) in prior litigation—often the correct doctrine when a plaintiff repeats
state-court claims in federal court.
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With prejudice vs. without prejudice: “With prejudice” is a merits-ending disposition that prevents
refiling. “Without prejudice” means the court did not decide the merits; the plaintiff may refile if a valid
jurisdictional basis exists (though other doctrines like preclusion may still block recovery).
Conclusion
Sungsuk Kim v. Unlimited Settlement Services underscores a foundational rule of federal litigation: a plaintiff must
affirmatively plead a basis for federal subject-matter jurisdiction, and failure to do so requires dismissal. Even where a
district court invokes Rooker-Feldman, appellate review may affirm on the more basic ground that jurisdiction was never
invoked. Finally, the decision reinforces that jurisdictional dismissals must be entered without prejudice, as they
do not adjudicate the merits—an important corrective with practical consequences for judgment form and future litigation posture.