Rooker-Feldman Doctrine: Difference between revisions
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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."<ref>Exxon Mobile Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, at 292 (2005)</ref> | 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."<ref>Exxon Mobile Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, at 292 (2005)</ref> | ||
In Skinner v. Switzer <ref>Skinner v. Switzer, 562 U.S. ___ (2011)</ref> 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."<ref> Skinner v. Switzer, 562 U.S. ____ (2011)<ref> 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. | |||
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Revision as of 09:30, 8 March 2011
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."<ref> Skinner v. Switzer, 562 U.S. ____ (2011)<ref> 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
