Page:Reed v. Goertz.pdf/14

6 The district attorney moved to dismiss Reed’s complaint for lack of subject-matter jurisdiction and for failure to state a claim. See Fed. Rule Civ. Proc. 12(b)(1) and (b)(6). The District Court held that it had jurisdiction but dismissed Reed’s complaint on the merits, concluding that Reed had alleged only “that he disagree[d] with the state court’s construction of Texas law” and that none of the issues in the complaint “r[ose] to the level of a procedural due-process violation.” 2019 WL 12073901, *7 (WD Tex., Nov. 15, 2019). The Fifth Circuit affirmed on the alternative ground that Reed’s claim was untimely: Applying Texas’ 2-year statute of limitations for personal-injury claims, it reasoned that Reed’s due process claim accrued when the trial court first denied his Chapter 64 motion, rendering his complaint several years too late. 995 F. 3d 425, 431 (2021).

Two intertwined principles of federal jurisdiction—Article III standing and the Rooker–Feldman doctrine —mandate a finding that the District Court lacked jurisdiction over this action. The majority gives short shrift to these principles, and its holding that Reed’s claim was timely serve only to underscore its antecedent jurisdictional errors.

The Constitution limits the federal courts’ jurisdiction to “Cases” and “Controversies,” Art. III, §2, cl. 1, constraining judicial power to “the determination of real, earnest and vital controvers[ies] between” contending litigants. Chicago & Grand Trunk R. Co. v. Wellman, 143 U. S. 339, 345 (1892). “[A]n essential and unchanging part of [this] case-or-controversy requirement” is the doctrine of Article III standing. Lujan v. Defenders of Wildlife, 504 U. S. 555, 560