Rooker-Feldman Doctrine Law and Legal Definition
Rooker Feldman doctrine is a legal principle that a federal court do not have jurisdiction to review decisions of state courts or claims inextricably intertwined with an earlier state-court judgment. The federal claim is inextricably intertwined with the state-court judgment if the federal claim succeeds only to the extent that the state court wrongly decided the issues before it. Where federal relief can only be predicated upon a conviction that the state court was wrong, it is difficult to conceive the federal proceeding as, in substance, anything other than a prohibited appeal of the state-court judgment. [Stemler v. City of Florence, 350 F.3d 578 (6th Cir. Ky. 2003)]
The Rooker-Feldman doctrine gets its name from two United States Supreme Court cases;Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) andD.C. Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983). The first case held that the power to hear appeals from state court judgments is exclusively held by the United States Supreme Court. The United States Supreme Court held in the second case that federal district courts do not have jurisdiction to hear challenges to certain state-court decisions.
The doctrine deprives federal courts of subject matter jurisdiction where a party, dissatisfied with a result in state court, sues in federal court seeking to set aside the state-court judgment and requesting a remedy for an injury caused by that judgment. If the injury the plaintiff complains of resulted from, or is inextricably intertwined with, a state-court judgment, then lower federal courts cannot hear the claim. However the Rooker-Feldman doctrine is inapplicable, when the alleged injury is distinct from the judgment. For instance, it is inapplicable when the federal claim alleges a prior injury that a state court failed to remedy. To determine whether Rooker-Feldman bars a claim, a court looks beyond the four corners of the complaint to discern the actual injury claimed by the plaintiff. A litigant may not attempt to circumvent the effect of Rooker-Feldman and seek a reversal of a state court judgment simply by casting the complaint in the form of a civil rights action. [Johnson v. Orr, 551 F.3d 564 (7th Cir. Ill. 2008)]
