Rooker-Feldman doctrine
Encyclopedia
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
(1923) and District of Columbia Court of Appeals v. Feldman
, 460 U.S. 462
(1983). The doctrine holds that lower United States federal courts
other than the Supreme Court
should not sit in direct review of state court decisions unless Congress has specifically authorized such relief. In short, a federal court must not become a court of appeals for a state court decision. The state court plaintiff has to find a state court remedy.
An example of legislation that has been interpreted to this effect is , which authorizes federal courts to grant writs of habeas corpus
. Another explicit legislative exception to this doctrine was the "Palm Sunday Compromise
," a statute passed by Congress to permit federal courts to review the decisions of Florida
courts in the Terri Schiavo
case.
The doctrine has been held to apply to any state court decisions that are judicial in nature. For example, a judge's decision not to hire an applicant for a job is not a "judicial" decision.
In 2005 the Supreme Court revisited the doctrine in Exxon Mobil Corp. v. Saudi Basic Industries Corp.
, 544 U.S. 280
. The Court affirmed that the Rooker-Feldman doctrine was statutory (based on the certiorari jurisdiction statute), and not constitutional, holding that it applies only in cases "brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments."
The Supreme Court has continued to narrow the doctrine, as in Lance v. Dennis, 126 S. Ct. 1198
(2006), and seems to want to minimize the use of the doctrine. For a mock obituary of the doctrine, see Samuel Bray, Rooker Feldman (1923-2006) 9 Green Bag
2d 317.
The Rooker-Feldman doctrine is related to the Anti-Injunction Act
, a federal statute which prohibits federal courts from issuing injunctions which stay lawsuits that are pending in state courts. Title 28, United States Code, Section 2283 reads:
Civil procedure
Civil procedure is the body of law that sets out the rules and standards that courts follow when adjudicating civil lawsuits...
enunciated by the United States Supreme Court in two cases, 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
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1923) and District of Columbia Court of Appeals v. Feldman
District of Columbia Court of Appeals v. Feldman
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 , 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 District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), was a case...
, 460 U.S. 462
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1983). 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:...
other than the Supreme 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...
should not sit in direct review of state court decisions unless Congress has specifically authorized such relief. In short, a federal court must not become a court of appeals for a state court decision. The state court plaintiff has to find a state court remedy.
An example of legislation that has been interpreted to this effect is , which authorizes federal courts to grant writs of habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
. Another explicit legislative exception to this doctrine was the "Palm Sunday Compromise
Palm Sunday Compromise
The Palm Sunday Compromise, formally known as the Act for the relief of the parents of Theresa Marie Schiavo, is an Act of Congress passed on March 21, 2005, to allow the case of Terri Schiavo to be moved into a federal court...
," a statute passed by Congress to permit federal courts to review the decisions of Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
courts in the Terri Schiavo
Terri Schiavo
The Terri Schiavo case was a legal battle in the United States between the legal guardians and the parents of Teresa Marie "Terri" Schiavo that lasted from 1998 to 2005...
case.
The doctrine has been held to apply to any state court decisions that are judicial in nature. For example, a judge's decision not to hire an applicant for a job is not a "judicial" decision.
In 2005 the Supreme Court revisited the doctrine in Exxon Mobil Corp. v. Saudi Basic Industries Corp.
Exxon Mobil Corp. v. Saudi Basic Industries Corp.
Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 , is a case in which the Supreme Court of the United States clarified the Rooker-Feldman doctrine and its relation to preclusion and concurrent jurisdiction.-Facts & Procedural Posture:...
, 544 U.S. 280
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
. The Court affirmed that the Rooker-Feldman doctrine was statutory (based on the certiorari jurisdiction statute), and not constitutional, holding that it applies only in cases "brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments."
The Supreme Court has continued to narrow the doctrine, as in Lance v. Dennis, 126 S. Ct. 1198
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), and seems to want to minimize the use of the doctrine. For a mock obituary of the doctrine, see Samuel Bray, Rooker Feldman (1923-2006) 9 Green Bag
The Green Bag
The Green Bag: An Entertaining Journal of Law is a legal journal supported in part by George Mason University School of Law and is dedicated to publishing "good writing" about the law. Founded in 1997 by three former-classmates of the University of Chicago Law School , The Green Bag is published...
2d 317.
The Rooker-Feldman doctrine is related to the Anti-Injunction Act
Anti-Injunction Act
The Anti-Injunction Act, , is a United States federal statute that prohibits any federal court from issuing an injunction against proceedings in any state court, except within three specifically defined exceptions...
, a federal statute which prohibits federal courts from issuing injunctions which stay lawsuits that are pending in state courts. Title 28, United States Code, Section 2283 reads:
A court of the United States may not grant an injunction to stay proceedings in a State court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments.