Rooker–Feldman Doctrine Explained

Rooker–Feldman Doctrine Explained

Under the Rooker-Feldman doctrine, federal district courts lack jurisdiction over "federal complaints ... that essentially invite federal courts of first instance to review and reverse unfavorable state-court judgments."

See:

(1) D.C. Court of Appeals v. Feldman, 460 U.S. 462, 103 S.Ct. 1303, 75 L.Ed.2d 206 (1983);

(2) Rooker v. Fid. Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923).

The jurisdictional statute providing for Supreme Court review of state court judgments states that "final judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court by writ of certiorari" when certain federal questions are presented. 28 U.S.C. § 1257;<#fn5> see also id. § 1258 (same for Puerto Rico Supreme Court).

Rooker held that Congress, by the terms of that statute, granted the United States Supreme Court, and only the United States Supreme Court, jurisdiction over appeals from state courts:

If the constitutional questions stated in the federal complaint actually arose in the state case, it was the province and duty of the state courts to decide them; and their decision, whether right or wrong, was an exercise of jurisdiction.... Under the legislation of Congress, no court of the United States other than this Court could entertain a proceeding to reverse or modify the judgment for errors of that character. To do so would be an exercise of appellate jurisdiction. The jurisdiction possessed by the District Courts is strictly original. (263 U.S. at 415-16, 44 S.Ct. 149.)

In other words, Rooker is based on a negative inference: because Congress only provided for review of state court judgments by the Supreme Court, Congress therefore intended to preclude lower federal courts from exercising such review.

Feldman repeated this reasoning: "A United States District Court has no authority to review final judgments of a state court in judicial proceedings. Review of such judgments may be had only in this Court." (460 U.S. at 482, 103 S.Ct. 1303.)