Raymond Greene v. Wesley Pipes

25-11764 Opinion of the Court 3 requested documents were unavailable. Greene soon thereafter pe- titioned the Alabama Supreme Court for a writ of mandamus or- dering state officials to provide him with the requested documents. This petition was ultimately transferred to Judge Wesley Pipes, the presiding judge for the Mobile County Circuit Court, who denied relief.

Just days later, Greene made another request for mandamus relief, asking that Judge Pipes be directed to set aside his order. The Alabama Court of Criminal Appeals denied this request, reasoning that Greene had an adequate remedy because he could have di- rectly appealed Judge Pipes's order. Greene then petitioned the Al- abama Supreme Court for certiorari, which the court construed as a mandamus petition and denied.

During this time, Greene also filed a "complaint" in state court pursuant to Alabama Rule of Civil Procedure 60(b). The complaint named Assistant District Attorney Nicki Patterson and alleged that prosecutorial misconduct caused his first criminal trial to end in a mistrial. Greene also contended that his retrial, which resulted in his instant convictions, violated the Fifth Amendment's Double Jeopardy Clause. The state court dismissed the complaint, and the Alabama Supreme Court affirmed.

B. District Court Proceedings

While his Rule 60(b) appeal was pending in state court, Greene initiated federal proceedings against several Alabama offi- cials. In his operative, amended 42 U.S.C. § 1983 complaint, Greene appeared to challenge the integrity of his civil and criminal state

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4 Opinion of the Court 25-11764 court proceedings. In relevant part, Greene alleged that the proce- dures used in reviewing his filings were contrary to the First, Fifth, and Fourteenth Amendments, and were "arbitrary" and "capri- cious," as they failed to provide an adequate remedy at law and denied litigants access to the courts and to relevant evidence. Greene maintained that these constitutional violations required

"declaratory-injunctive" relief and "equitable intervention."

Acting sua sponte, a magistrate judge recommended dismis- sal of the action for lack of subject matter jurisdiction. The magis- trate judge interpreted the complaint as "broadly request[ing] in- junctive relief." The magistrate judge further interpreted the com- plaint as specifically requesting the court to order the production of the state court records Greene was denied and to determine whether there was prosecutorial misconduct at his original trial. With this understanding, the magistrate judge determined that Greene's complaint fell within the scope of the Rooker-Feldman doc- trine. The magistrate judge noted that Greene "made conclusory allegations of constitutional violations," but found that the com- plaint "c[ould] only be read as a de facto appeal [of] state court judg- ments."

Over Greene's objections, the district judge adopted the magistrate judge's recommendation and dismissed the action with- out prejudice. In addition to the magistrate judge's conclusions, the district judge noted that, to the extent Greene's complaint could be construed as seeking habeas relief, such claims would be untimely, impermissibly successive, and meritless.

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25-11764 Opinion of the Court 5 This appeal followed.

II. STANDARD OF REVIEW

We review de novo a district court's determination that it lacks subject matter jurisdiction over a case based upon the princi- ples of the Rooker-Feldman doctrine. Behr v. Campbell, 8 F.4th 1206, 1209 (11th Cir. 2021).

III. DISCUSSION

The Rooker-Feldman doctrine precludes a district court from exercising subject matter jurisdiction over "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings com- menced and inviting district court review and rejection of those judgments." T.M. v. Univ. of Md. Med. Sys. Corp., 146 S. Ct. 1739, 1744 (2026) (quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp.,

544 U.S. 280, 284 (2005)). Rooker-Feldman "bars all appeals of state court judgments—whether the plaintiff admits to filing a direct ap- peal of the judgment or tries to call the appeal something else."

Behr, 8 F.4th at 1211. The doctrine also applies "regardless of whether [the complained-of] judgments are final trial-court judg- ments or those of a State's highest court." T.M., 146 S. Ct. at 1752. But Rooker-Feldman "does not prevent a district court from exercising subject-matter jurisdiction simply because a party at- tempts to litigate in federal court a matter previously litigated in state court." Efron v. Candelario, 110 F.4th 1229, 1235 (11th Cir. 2024) (citation modified), cert. denied, 145 S. Ct. 1958 (2025). "Nor

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6 Opinion of the Court 25-11764 does Rooker-Feldman block claims that require some reconsidera- tion of a decision of a state court if the plaintiff presents some inde- pendent claim, albeit one that denies a legal conclusion that a state court has reached in a case to which he was a party." Id. (citation modified). "Indeed, we have stated that Rooker-Feldman 'will almost never apply.'" Id. (quoting Behr, 8 F.4th at 1212). We conclude that this is one of those cases where the Rooker-Feldman doctrine is in- applicable.

We must liberally construe Greene's amended complaint. Campbell v. Air Jam. Ltd., 760 F.3d 1165, 1168 (11th Cir. 2014). So construed, Greene alleged constitutional violations associated with the resolutions of his records requests, petitions for mandamus re- lief, and request for Rule 60(b) relief filed in the state courts. And, contrary to the district court's conclusion, Greene sought both "de- claratory-injunctive" relief and "equitable intervention" related to these arguments. Rooker-Feldman did not strip the district court of subject matter jurisdiction to evaluate Greene's requests for declar- atory relief related to these alleged violations of his constitutional rights. See Efron, 110 F.4th at 1235.

The source of Greene's alleged injuries was not exclusively the adverse resolution of his state court actions, but also the proce- dures by which Alabama officials evaluated his filings. See id. at 1236. For example, Greene's operative complaint pointed to Ala- bama's "processes" in the adjudication of his mandamus petitions and Rule 60(b) filing, alleging they were inadequate and contrary to principles of federal law. Greene also claimed that Alabama's

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25-11764 Opinion of the Court 7 processes were "arbitrary" and "capricious" and that they failed to provide litigants an adequate remedy at law. While these argu- ments suggest that Greene was unhappy with the results of his state actions, construing the entirety of his case as directly appealing those state judgments would be too broad an interpretation of the pleadings. We therefore conclude that Greene's constitutional challenges fall outside the "narrow ground" occupied by Rooker- Feldman. Behr, 8 F.4th at 1209 (citation omitted); see also Efron,

110 F.4th at 1235. We note that "[o]ther preclusion and abstention doctrines remain alive and well," and we leave to the district court to deter- mine in the first instance whether Greene's action is subject to dis- missal on some other basis. Behr, 8 F.4th at 1214; see also Exxon Mobil Corp., 544 U.S. at 293 ("If a federal plaintiff presents some independ- ent claim, albeit one that denies a legal conclusion that a state court has reached in a case to which he was a party, then there is jurisdic- tion and state law determines whether the defendant prevails un- der principles of preclusion." (citation modified)).

IV. CONCLUSION

We VACATE the district court's order dismissing Greene's complaint for lack of subject matter jurisdiction. This case is

REMANDED for further proceedings consistent with this opinion.

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