Mo’s Express, LLC v. Sopkin

Colorado state law required companies that transported people intrastate on public highways to obtain state-issued certificates of public convenience and necessity (the state certificates) from the Colorado Public Utilities Commission (the commission) (defendant). Federal law required companies that transported people interstate on public highways to obtain federal certificates from the Federal Motor Carrier Safety Administration. The federal certificates allowed companies to provide intrastate transport if the companies also provided regular interstate transport. In 1999 the commission issued notices to certain shuttle services that had federal certificates and that provided substantial intrastate transportation to and from the Denver International Airport (the airport) alleging the shuttle services were not conducting the interstate transport required by federal law. The commission planned to fine the shuttle services. The shuttle services argued that state law regarding the transportation certificates was preempted by federal law, and therefore, the commission did not have authority to police the services’ compliance with their federal certificates. Eventually, the Colorado Supreme Court held that the commission did have jurisdiction over the services and upheld the commission’s imposition of fines. After the state case ended, Mo’s Express, LLC (Mo’s) and 12 other companies that provided airport shuttle service (collectively, the plaintiff shuttle services) (plaintiffs) filed a case in federal district court against the commission, making the same arguments as the state case and seeking a prospective injunction and declaratory relief against the commission. Mo’s was the only company of the plaintiff shuttle services that had been involved in the state case. The district court dismissed the case, citing the Rooker-Feldman doctrine, which prohibited federal district courts from exercising appellate jurisdiction over state-court decisions. The plaintiff shuttle services appealed.