District of Columbia Court of Appeals v. Feldman
Encyclopedia
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), was a case decided by the United States Supreme Court
in which the Court enunciated a rule of civil procedure
known as the Rooker-Feldman doctrine
(also named for the earlier case of Rooker v. Fidelity Trust Co.
, 263 U.S. 413 (1923). The doctrine holds that lower United States federal courts
may not sit in direct review of state court decisions.
enacted several pieces of legislation with respect to Washington, D.C.
's local judicial system. One required final judgments from the District of Columbia Court of Appeals
to be treated like final judgments from the high court of any state; another permitted that Court of Appeals to create rules governing the qualifications and admissions of attorneys to practice in the D.C. courts. The Court of Appeals then passed rules requiring applicants to the D.C. bar to have graduated from an ABA-accredited law school
.
The plaintiffs - Feldman and Hickey - were practicing attorneys from other states, but neither had graduated from ABA
-accredited law schools. Feldman had been admitted to the Virginia
bar through an apprenticeship, and had been admitted to the Maryland
bar through a waiver of their requirements, based on his personal experience. Feldman was denied admission by the Committee on Admissions of the District of Columbia Bar, so he sought a similar waiver of the D.C. rule, sending a letter to the D.C. Court of Appeals that suggested that their absolute prohibition of lawyers who had not attended certain schools was a violation of the Sherman Antitrust Act
, and of the Fourteenth Amendment
. Nevertheless, the D.C. Courts issued an opinion confirming that they would not waive their requirement. Hickey had a similar background, but did not suggest that the D.C. Court of Appeals was in violation of any laws.
The plaintiff then filed an action in the U.S. District Court for the District of Columbia, which denied jurisdiction based on Rookers prohibition against federal courts hearing appeals of state court judgments. The U.S. Court of Appeals for the District of Columbia reversed, saying that this was not the kind of judicial determination that a federal court would be barred from hearing on appeal from a decision of a state court.
, held that the District Court had properly dismissed the case for lack of jurisdiction
to hear an appeal of the highest court in a state. The denial of a waiver for admission to the bar, an evaluation of specific facts in light of an existing rule of law, was a judicial determination, only appealable to the Supreme Court.
The Court noted, however, that a facial challenge to the constitutionality of the law would not be considered a review of anything that had been decided by the D.C. Court of Appeals, and remanded this question to the lower court.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
in which the Court enunciated a rule of civil procedure
Civil procedure
Civil procedure is the body of law that sets out the rules and standards that courts follow when adjudicating civil lawsuits...
known as the Rooker-Feldman doctrine
Rooker-Feldman doctrine
The Rooker-Feldman doctrine is a rule of civil procedure enunciated by the United States Supreme Court in two cases, Rooker v. Fidelity Trust Co., 263 U.S. 413 and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462...
(also named for the earlier case of Rooker v. Fidelity Trust Co.
Rooker v. Fidelity Trust Co.
Rooker v. Fidelity Trust Co., 263 U.S. 413 , was a case in which the United States Supreme Court enunciated a rule of civil procedure that would eventually become known as the Rooker-Feldman doctrine Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), was a case in which the United States Supreme...
, 263 U.S. 413 (1923). The doctrine holds that lower United States federal courts
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
may not sit in direct review of state court decisions.
Facts
The U.S. CongressUnited States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
enacted several pieces of legislation with respect to Washington, D.C.
Washington, D.C.
Washington, D.C., formally the District of Columbia and commonly referred to as Washington, "the District", or simply D.C., is the capital of the United States. On July 16, 1790, the United States Congress approved the creation of a permanent national capital as permitted by the U.S. Constitution....
's local judicial system. One required final judgments from the District of Columbia Court of Appeals
District of Columbia Court of Appeals
The District of Columbia Court of Appeals is the highest court of the District of Columbia. Established by the United States Congress in 1970, it is equivalent to a state supreme court, except that its power derives from Article I of the U.S. Constitution rather than from the inherent sovereignty...
to be treated like final judgments from the high court of any state; another permitted that Court of Appeals to create rules governing the qualifications and admissions of attorneys to practice in the D.C. courts. The Court of Appeals then passed rules requiring applicants to the D.C. bar to have graduated from an ABA-accredited law school
Law school
A law school is an institution specializing in legal education.- Law degrees :- Canada :...
.
The plaintiffs - Feldman and Hickey - were practicing attorneys from other states, but neither had graduated from ABA
American Bar Association
The American Bar Association , founded August 21, 1878, is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. The ABA's most important stated activities are the setting of academic standards for law schools, and the formulation...
-accredited law schools. Feldman had been admitted to the Virginia
Virginia
The Commonwealth of Virginia , is a U.S. state on the Atlantic Coast of the Southern United States. Virginia is nicknamed the "Old Dominion" and sometimes the "Mother of Presidents" after the eight U.S. presidents born there...
bar through an apprenticeship, and had been admitted to the Maryland
Maryland
Maryland is a U.S. state located in the Mid Atlantic region of the United States, bordering Virginia, West Virginia, and the District of Columbia to its south and west; Pennsylvania to its north; and Delaware to its east...
bar through a waiver of their requirements, based on his personal experience. Feldman was denied admission by the Committee on Admissions of the District of Columbia Bar, so he sought a similar waiver of the D.C. rule, sending a letter to the D.C. Court of Appeals that suggested that their absolute prohibition of lawyers who had not attended certain schools was a violation of the Sherman Antitrust Act
Sherman Antitrust Act
The Sherman Antitrust Act requires the United States federal government to investigate and pursue trusts, companies, and organizations suspected of violating the Act. It was the first Federal statute to limit cartels and monopolies, and today still forms the basis for most antitrust litigation by...
, and of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
. Nevertheless, the D.C. Courts issued an opinion confirming that they would not waive their requirement. Hickey had a similar background, but did not suggest that the D.C. Court of Appeals was in violation of any laws.
The plaintiff then filed an action in the U.S. District Court for the District of Columbia, which denied jurisdiction based on Rookers prohibition against federal courts hearing appeals of state court judgments. The U.S. Court of Appeals for the District of Columbia reversed, saying that this was not the kind of judicial determination that a federal court would be barred from hearing on appeal from a decision of a state court.
Issue
The Supreme Court considered in this case whether the district court had jurisdiction to review this decision, which required an inquiry into whether the decision to be reviewed is a "judicial" decision, or one that is merely administrative.Result
The Supreme Court, in an opinion by Justice BrennanWilliam J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
, held that the District Court had properly dismissed the case for lack of jurisdiction
Jurisdiction
Jurisdiction is the practical authority granted to a formally constituted legal body or to a political leader to deal with and make pronouncements on legal matters and, by implication, to administer justice within a defined area of responsibility...
to hear an appeal of the highest court in a state. The denial of a waiver for admission to the bar, an evaluation of specific facts in light of an existing rule of law, was a judicial determination, only appealable to the Supreme Court.
The Court noted, however, that a facial challenge to the constitutionality of the law would not be considered a review of anything that had been decided by the D.C. Court of Appeals, and remanded this question to the lower court.
Dissent
Justice Stevens dissented, noting that each plaintiff had asked the Court of Appeals to exercise administrative discretion by waiving the requirements, but neither plaintiff had actually sought review of the rule of law itself. Although Feldman had suggested that the rule was in violation of the law, he had not asked for the Court of Appeals to rule that it was, but had merely indicated a challenge that he might bring in the federal district court.See also
- Admission to the bar in the United StatesAdmission to the bar in the United StatesIn the United States, admission to the bar is the granting of permission by a particular court system to a lawyer to practice law in that system. Each U.S. state and similar jurisdiction has its own court system and sets its own rules for bar admission , which can lead to different admission...
- List of United States Supreme Court cases, volume 460