Shelby County Health Care Corp. v. Southern Farm Bureau Casualty

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The court vacated the dismissal of The Med's claim of alleged impairment of a hospital lien, concluding that the claim was not barred by the Rooker-Feldman doctrine. The court explained that to apply Rooker-Feldman in this case to a non-party who had an opportunity to intervene in state-court proceedings would echo the pre- Exxon Mobil Corp. v. Saudi Basic Indus. Corp. lower-court rulings that expanded the doctrine too far. Here, the Med did not seek to reverse the order of the Arkansas state court, and acknowledged that it could not seek a judgment directly against the proceeds of the personal injury settlement. The court also concluded that the district court erred by alternatively ruling that Arkansas law applied to the dispute between the parties. Rather, the court applied a choice-of-law analysis and concluded that Tennessee law applied in this case. View "Shelby County Health Care Corp. v. Southern Farm Bureau Casualty" on Justia Law