Jurisdiction, Abstention, and Finality: Articulating a Unique Role for the Rooker-Feldman Doctrine

Abstract

Federal courts frequently confuse the Rooker-Feldman doctrine with Younger abstention and preclusion law, often using these doctrines interchangeably to dismiss actions that would interfere with state court proceedings. For years, scholars argued that the Supreme Court should alleviate this confusion by abolishing the Rooker-Feldman doctrine altogether. The Court recently refused to so, however. In Exxon Mobil Corp. v. Saudi Basic Industries Corp. and Lance v. Dennis, the Court reaffirmed Rooker-Feldman’s vitality, and held that the doctrine plays a unique role, completely separate from abstention and preclusion rules. And yet these decisions leave a key question unanswered: exactly how does Rooker-Feldman interact with Younger abstention and preclusion law? This Article explores the relationship between these three doctrines, and articulates two unique roles that Rooker-Feldman can play. First, Rooker-Feldman is the only doctrine that bars federal court claims complaining of injuries caused by final state court judgments. Second, in the context of civil actions and claims for monetary relief, Rooker-Feldman is the only doctrine that bars litigants from collaterally attacking non-final judgments.

Keywords: Rooker-Feldman, Younger, preclusion, res judicata, collateral estoppel, jurisdiction, abstention, federal courts, judgment, appellate review, finality, federalism, separation of powers, parity