Legal Memorandum: Rooker-Feldman Doctrine

Issue: Under federal law, what is the Rooker-Feldman Doctrine?

The Rooker-Feldman doctrine is a jurisdictional bar to lower federal courts hearing certain claims and is closely related to concept of abstention.  It is a logical extension of 28 U.S.C. § 1257, which states that the Supreme Court has exclusive authority to review judgments of the highest State court for constitutionality.  As its name suggests, this doctrine derives from Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983).  Since lower federal courts lack this appellate authority, the Rooker-Feldman doctrine prohibits “a party losing in state court . . . from seeking what in substance would be appellate review of the state judgment in a United States district court, based on the losing party’s claim that the state judgment itself violates the loser’s federal rights.”  Johnson v. DeGrandy, 512 U.S. 997, 1005–06 (1994) (citation omitted); Knox v. Bland, 632 F.3d 1290, 1292 (10th Cir. 2011). 

The doctrine applies and bars lower federal courts from hearing an action when the following criteria are met: (1) plaintiff lost in state court; (2) the plaintiff complains of injuries caused by a state court judgment; (3) plaintiff invites federal district court review and rejection of that state court judgment; and (4) the state court judgment was rendered prior to the start of the federal proceedings.  Green v. Mattingly, 585 F.3d 97, 101 (2d Cir. 2009).

There are limits on the doctrine’s application.  For one, it has generally […]