Nahmod Law

Federal Courts Do Not Have Appellate Jurisdiction Over State Court Judgments

Despite the broad grants to federal courts of jurisdiction over section 1983 claims by 28 U.S.C. §§1331 and 1343, there are circumstances where federal jurisdiction over such claims is absent. Under the Rooker-Feldman doctrine–see District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 1983)–federal courts have no appellate jurisdiction over state court judgments with respect to modifying or vacating them.

Explaining the proper scope of this doctrine in Exxon Mobil v. Saudi Basic Industries Corp., 125 S. Ct. 1517 (2005), the Supreme Court observed that Rooker-Feldman “has sometimes been construed to extend far beyond the contours of the Rooker and Feldman cases, overriding Congress’ conferral of federal-court jurisdiction concurrent with jurisdiction exercised by state courts, and superseding the ordinary application of preclusion law pursuant to 28 U.S.C. 1738.” After extensive analysis of the doctrine, the Court declared, 125 S. Ct. at 1521-22 (emphasis added):

The Rooker-Feldman doctrine, we hold today, is confined to cases of the kind from which the doctrine acquired its name: 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. Rooker-Feldman does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions.

The Court in Exxon Mobil went on to emphasize that when there is parallel state and federal litigation, as in the case before it, Rooker-Feldman was not triggered just by the entry of judgment in the state court proceeding. Rather, preclusion law would then be applicable. Accordingly, the Court reversed the Third Circuit which had ruled in erroneous reliance on Rooker-Feldman that the district court’s jurisdiction terminated once the state court entered judgment. The Court pointed out that the litigant in the federal action was not seeking to overturn the state court judgment.

The Seventh Circuit’s Approach

By way of a pre-Exxon Mobil general approach to Rooker-Feldman issues that is still good law, the Seventh Circuit suggested that federal courts must closely examine section 1983 complaints to determine whether it is the underlying procedure that is challenged as unconstitutional or the state court judgment in the case. “The fundamental and appropriate question to ask is whether the injury alleged by the federal plaintiff resulted from the state court judgment itself or is distinct from that judgment.” Gerry v. Geils, 82 F.3d 1362, 1365 (7th Cir. 1996).

A recent example of this approach is a decision in which the Seventh Circuit found Rooker-Feldman applicable to the section 1983 federal court claims of motorists who were stopped and later convicted of traffic violations and who sued various local and state officials, alleging that the defendants engaged in a wide-ranging conspiracy to deprive them of their constitutional rights. “[T]he plaintiffs lost in state court, their injuries flowed by the state-court judgments, the injuries occurred prior to the federal proceedings, and they want the federal courts to review and reject the state-court judgments.” Lennon v. City of Carmel,Indiana, 2017 WL 3140942, *2 (7th Cir. 2017).

Rooker-Feldman Found Inapplicable in Third Circuit Decision

In contrast, in a recent Third Circuit  section 1983 case, fathers of minor children brought actions seeking declaratory and injunctive relief against various defendants, including state court judges, alleging that custody standards violated the Fourteenth Amendment. Finding Rooker-Feldman inapplicable, although ultimately ruling for the defendants, the Third Circuit pointed out that the plaintiffs did not challenge state court judgments but the underlying policy that governed them, namely, allegedly stripping parents of custody in favor of other parents without a plenary hearing and using an improper best-interests-of-the-child standard. Allen v. DeBello, 2017 WL 2766365 (3^rd Cir. 2017).

Comment

Needless to say, but I’ll say it anyway, section 1983 litigants in federal court should be sensitive to the possible application of Rooker-Feldman whenever there is a state court judgment that may be implicated by the federal court litigation. Those who want to know more about this complicated subject can check out the analysis and collected Rooker-Feldman cases in my treatise, CIVIL RIGHTS AND CIVIL LIBERTIES LITIGATION: THE LAW OF SECTION 1983 secs. 1:26-1:30  (2017)(West/Westlaw).

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