The Rooker-Feldman Doctrine
The Rooker-Feldman doctrine stems from the federal statutory provision that the United States Supreme Court may review state court judgments through a writ of certiorari. 28 U.S.C. 1257(a) (2001).
From this starting point, the United States Supreme Court announced in Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), that a federal district court correctly dismissed a petition seeking to set aside a state court judgment on constitutional grounds because the United States Supreme Court is the only federal court with the power to set aside or modify state court judgments.
In District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), the United States Supreme Court extended the rule that "lower federal courts possess no power whatever to sit in direct review of state court decisions" to encompass claims that are "inextricably intertwined with" a state court judgment. Id. at 483 n.16.
The Rooker-Feldman doctrine is a jurisdictional bar. See Pittsburg County Rural Water Dist. No. 7, 358 F.3d at 705, 707.