The Rooker-Feldman Doctrine

Abstract

The Rooker-Feldman Doctrine stands for the principle that only the United States Supreme Court has appellate jurisdiction over state court judgments. To determine if the lower federal court is improperly reviewing a state court judgment the question arises if the claim in federal court is inextricably intertwined with the state court claim. Or, does the federal plaintiff present an independent claim. However, there is in consistent application of the proper scope of this pivotal element among the circuit courts.

This article sets out the differences of the 2nd, 5th, 6th, 7th and 9th circuits.

The Rooker-Feldman Doctrine bars a party losing in state court from seeking appellate review of a state court judgment in a United States district court. This based on lack of subject matter jurisdiction.

Keywords: Federal Court, Appellate Jurisdiction, Subject Matter Jurisdiction, Judgments