What Is the Rooker-Feldman Doctrine ?
The Rooker-Feldman doctrine is the namesake of Rooker v. Fidelity Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 103 S.Ct. 1303, 75 L.Ed.2d 206 (1983).
In Rooker, the plaintiffs brought suit in federal district court seeking a declaration that a state-court judgment against them was "null and void" because, they alleged, it was in violation of the Constitution. Id. at 414-15, 44 S.Ct. 149.
The Supreme Court concluded that the district court lacked subject-matter jurisdiction over the claim because "under the legislation of Congress, no court of the United States other than this court could entertain a proceeding to reverse or modify a state-court judgment for errors of Constitutional character." Id. at 416, 44 S.Ct. 149.
In Feldman, the plaintiffs brought suit in federal district court against the District of Columbia Court of Appeals alleging (1) the District of Columbia court's rule prohibiting those who had not graduated from law school from becoming members of the bar violated federal constitutional and statutory law and (2) the District of Columbia court's denial of their petitions for a waiver from the bar-admission rule also violated federal constitutional and statutory law. Id. at 468, 103 S.Ct. 1303.
The Supreme Court held that the district court had subject-matter jurisdiction to consider the plaintiffs' first claim because the facial challenge to the rule was like any other challenge of any legislative enactment. Id. at 486, 103 S.Ct. 1303.
The second claim, however, was different. There, in ruling on the plaintiffs' application for a waiver, the District of Columbia court had acted in a judicial, rather than a legislative, capacity. Id. at 480-82, 103 S.Ct. 1303.
The plaintiffs' second claim challenged that judicial determination and therefore effectively sought appellate review of the District of Columbia court's ruling in the district court. Id. Because only the Supreme Court has appellate jurisdiction to review a state court's order, see 28 U.S.C.A. § 1257(a) (West 1993), the Supreme Court held that the district court lacked subject-matter jurisdiction to hear the plaintiffs' second claim. Id. at 482, 103 S.Ct. 1303.
In a cryptic footnote, the Supreme Court rejected the argument that the district court would have had subject-matter jurisdiction over the plaintiffs' second claim if the plaintiffs had failed to make their federal-law arguments to the state court, instead holding that "if the constitutional claims presented to the district court are inextricably intertwined with the state court's ruling in a judicial proceeding ..., then the district court is in essence being called upon to review the state court decision." Id. at 482, 103 S.Ct. 1303 n. 16.