Legal Definitions - Rooker–Feldman doctrine

The Rooker–Feldman doctrine is a legal principle that limits the authority of federal district courts. It states that federal district courts cannot review or overturn decisions made by state courts. This means that if a case has already been decided by a state court, a party who lost in that state court cannot then bring the same claims, or claims that are fundamentally linked to the state court's judgment, to a federal district court in an attempt to get a different outcome. Essentially, federal district courts are not meant to act as an appeals court for state court decisions.

Here are some examples to illustrate this doctrine:

• Example 1: Property Dispute

  Imagine a homeowner, Ms. Chen, is involved in a lengthy dispute with her neighbor over the exact boundary line between their properties. The case goes through the state court system, and the state's highest court ultimately rules in favor of the neighbor, establishing the boundary line. Ms. Chen, unhappy with this outcome, cannot then file a lawsuit in a federal district court arguing that the state court's decision on the boundary line violated her constitutional right to property. The Rooker–Feldman doctrine would prevent the federal court from hearing her case because it would require the federal court to review and effectively overturn a judgment already made by the state court.

• Example 2: Professional License Revocation

  Consider Dr. Miller, whose medical license is revoked by a state medical board after a series of hearings. Dr. Miller appeals this decision through the state court system, arguing that the process violated his due process rights under the U.S. Constitution. The state's highest court upholds the license revocation. Dr. Miller cannot then file a new lawsuit in a federal district court, alleging that the state court's decision to uphold the license revocation was unconstitutional. The Rooker–Feldman doctrine would apply because the federal court would be asked to re-examine and invalidate a judgment already rendered by the state court, which is an impermissible form of appellate review.

• Example 3: Contract Enforcement with Federal Defense

  A small business, "InnovateTech," is sued by a larger corporation for breach of contract in state court. InnovateTech defends itself by arguing that the contract itself is illegal under federal antitrust laws. The state court considers this defense but ultimately rules against InnovateTech, finding them liable for breach of contract. InnovateTech cannot then file a new lawsuit in federal district court, claiming that the state court's rejection of their federal antitrust defense was incorrect and therefore the state court's judgment should be set aside. The Rooker–Feldman doctrine would bar this federal action because the federal court would be asked to review a claim (the antitrust defense) that was either directly decided by the state court or is "inextricably intertwined" with the state court's final judgment on the contract dispute.