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Businesses often prefer to litigate in federal rather than state court. In three cases, the Supreme Court eased access to the federal courts. In Exxon Mobil Corp. v. Allapattah Services Inc., 125 S. Ct. 2611 (2005), the court, in a 5-4 opinion, held that as long as at least one named plaintiff satisfies the amount-in-controversy requirement of diversity jurisdiction, the court has supplemental jurisdiction over other plaintiffs’ claims arising from the same dispute (including those of absent class action plaintiffs), even if they do not satisfy that requirement. The court expanded opportunities for defendants unhappy with a state court forum to prosecute a parallel case in federal court in its unanimous decision in Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 125 S. Ct. 1517 (2005). The Rooker-Feldman doctrine denies federal district courts jurisdiction to review state court judgments; such jurisdiction is vested exclusively in the Supreme Court. The court interpreted the doctrine to mean that when there is parallel state and federal litigation and the state court reaches judgment on the same or related questions, the federal court still retains jurisdiction, and that ordinary rules of preclusion determine the impact of the state court judgment in federal court. In Grable & Sons Metal Products Inc. v. Darue Eng’g & Mfg., 125 S. Ct. 2363 (2005), the court held that a state court defendant can remove to federal court state law claims that necessarily raise a substantial federal issue when federal jurisdiction would not upset Congress’ judgment about the allocation of cases between state and federal courts. The court found federal jurisdiction because the federal issue lurking in the state claim-the meaning of federal tax law-involved important federal interests and would only rarely arise in state claims. It distinguished state tort claims premised on violations of federal safety regulations, noting that such claims do not present federal questions.

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