Barefoot v. City of Wilmington - Case Brief Summary (Federal Court)
In Barefoot v. City of Wilmington, 306 F.3d 113 (4th Cir. 2002), the city enacted an ordinance that allowed it to annex the plaintiffs’ land. Id. at 118.
The plaintiffs opposed the annexation, and filed suit in state court alleging that the ordinance violated state law. Id. at 119.
The state court disagreed and upheld the ordinance. Id. The plaintiffs then filed suit in the federal district court alleging that the ordinance violated several federal constitutional provisions. Id.
The district court denied the plaintiffs’ request for a temporary restraining order and an injunction, and the plaintiffs appealed. Id.
On appeal, the Court held that the Rooker-Feldman doctrine barred the suit, stating: The Rooker-Feldman doctrine generally bars district courts from sitting in direct review of state court decisions. The prohibition extends not only to issues actually decided by a state court but also to those that are inextricably intertwined with questions ruled upon by a state court. A federal claim is inextricably intertwined with a state court decision if success on the federal claim depends upon a determination that the state court wrongly decided the issues before it. Id. at 120.
Because the plaintiffs had the opportunity to raise their constitutional claims before the state courts, the Court held that their federal suit was inextricably intertwined with the state proceedings. Id. at 121.