Rooker-Feldman Doctrine

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The Rooker-Feldman Doctrine states that U.S. Federal Courts are jurisdictionally barred from deciding cases decided exclusively on state grounds. The doctrine rests on the premis that state courts are the authority on state laws and Federal Courts may not decide cases based on state law unless a Federal issue is raised separately. The name is based on two U.S. Supreme Court cases: Rooker v. Fidelity Trust Co. [1] and District of Columbia Court of Appeals v. Feldman [2]. In both of these cases the losing part in the state court filed suit in U.S. District court after the state proceedings ended, complaining of an injury caused by the state-court judgment.

Under this line of cases, Federal Courts do not have subject matter jurisdiction over such claims because 28 U.S.C. Section 1257, "vests authority to review a state court's judgment solely in this Court."[3]

In Skinner v. Switzer [4] the Court again revisisted the Rooker-Feldman Doctrine. In this case, the plaintiff challenged the constitutionality of a Texas state court procedure that denied him access to evidence that could be tested for DNA. The defendant argued that Skinner was merely challenging a state court decision and that his claim was jurisdictionally barred under the Rooker-Feldman Doctrine. The U.S. Supreme Court concluded that many federal courts had extended the doctrine "beyond the countours of the Rooker and Feldman cases."[5] and that it did not apply in this case because Skinner was challenging the constitutionality of the Texas statute under 42 U.S.C. § 1983, not the decision itself.


See Jurisdiction

Notes

  1. Rooker v. Fidelity Trust Co. , 263 U.S. 413 (1923)
  2. District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)
  3. Exxon Mobile Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, at 292 (2005)
  4. Skinner v. Switzer, 562 U.S. ___ (2011)
  5. Skinner v. Switzer, 562 U.S. ____ (2011)