Rooker-Feldman Doctrine
The Rooker-Feldman Doctrine states that U.S. Federal Courts are jurisdictionally barred from deciding cases decided exclusively on state grounds. 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