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Rooker-Feldman doctrine
From Wikipedia, the free encyclopedia
The Rooker-Feldman doctrine is a rule of civil procedure enunciated by the United States Supreme Court in two cases, Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983). The doctrine holds that lower United States federal courts have no subject matter jurisdiction to sit in direct review of state court decisions unless Congress has enacted legislation that specifically authorized such relief.
An example of legislation that has been interpreted to this effect is 28 U.S.C. § 2254, which authorizes federal courts to grant writs of habeas corpus. Another explicit legislative exception to this doctrine was the "Palm Sunday Compromise," a statute passed by Congress to permit federal courts to review the decisions of Florida courts in the Terri Schiavo case.
The doctrine has been held to apply to any state court decisions that are judicial in nature. For example, a judge's decision not to hire an applicant for a job is not a "judicial" decision.
In 2005, the Supreme Court revisited the doctrine in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005). The Court affirmed that the Rooker-Feldman doctrine was statutory (based on the certiorari jurisdiction statute, 28 U.S.C. § 1257), and not jurisdictional, holding that it applies only in cases "brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments."
The Supreme Court has continued to narrow the doctrine, as in Lance v. Dennis, 126 S. Ct. 1198 (2006), and seems to want to minimize the use of the doctrine. For a mock obituary of the doctrine, see Samuel Bray, Rooker Feldman (1923-2006) 9 Green Bag 2d 317.