District of Columbia Court of Appeals et al. v. Feldman et al.
460 U.S. 462 (1983)
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Rule of Law:
United States District Courts lack subject-matter jurisdiction to review final judgments of a state's highest court in judicial proceedings, such as denying a particular applicant admission to the bar. However, District Courts do have jurisdiction over general constitutional challenges to a state's bar admission rules.
Facts:
- Marc Feldman pursued a legal education through a structured apprenticeship program in Virginia rather than attending an ABA-approved law school.
- After passing the Virginia bar, Feldman was also admitted to the Maryland bar after Maryland's Board of Law Examiners granted him a waiver of its ABA-approved law school requirement.
- Feldman applied for admission to the District of Columbia Bar, which required graduation from an ABA-approved law school under its Rule 461(b)(3).
- The D.C. Committee on Admissions denied his application, leading Feldman to petition the District of Columbia Court of Appeals for a waiver of the rule, arguing his qualifications were equivalent.
- Edward Hickey attended the Potomac School of Law, an unaccredited institution, believing he could obtain a waiver based on the D.C. Court of Appeals' past practice of granting them to graduates of another unaccredited school.
- The D.C. Court of Appeals later announced it would cease granting such waivers.
- Hickey petitioned the D.C. Court of Appeals for a waiver of Rule 461(b)(3), arguing reliance on the court's prior policy and other equitable factors.
- The District of Columbia Court of Appeals denied both Feldman's and Hickey's petitions for waiver in separate orders.
Procedural Posture:
- Feldman and Hickey separately petitioned the District of Columbia Court of Appeals, the highest court for the District, for waivers of its bar admission rule.
- The D.C. Court of Appeals denied both petitions in separate per curiam orders.
- Feldman and Hickey each filed a complaint in the United States District Court for the District of Columbia against the D.C. Court of Appeals, alleging constitutional and antitrust violations.
- The U.S. District Court, as the trial court, dismissed both complaints for lack of subject-matter jurisdiction.
- Feldman and Hickey, as appellants, appealed to the United States Court of Appeals for the District of Columbia Circuit.
- The U.S. Court of Appeals, an intermediate appellate court, affirmed the dismissal of the antitrust claims but reversed the dismissal of the constitutional claims, reasoning that the waiver proceedings were non-judicial.
- The District of Columbia Court of Appeals, as petitioners, was granted a writ of certiorari by the United States Supreme Court.
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Issue:
Does a United States District Court have subject-matter jurisdiction to review a final decision of a jurisdiction's highest court denying a particular applicant's petition for waiver of a bar admission rule, or to hear a general constitutional challenge to the validity of that rule?
Opinions:
Majority - Justice Brennan
No, a United States District Court does not have jurisdiction to review the final judicial act of a state's highest court denying a specific bar applicant's waiver petition, but yes, it does have jurisdiction over general challenges to the constitutionality of the bar admission rule itself. A crucial distinction exists between judicial and nonjudicial proceedings. When the D.C. Court of Appeals evaluated Feldman's and Hickey's individual petitions and qualifications to decide whether to waive an existing rule, it was engaged in a judicial inquiry—adjudicating a present claim of right based on past and present facts. Under the doctrine established in Rooker v. Fidelity Trust Co., lower federal courts are barred from exercising appellate review over state-court judgments; such review lies exclusively with the U.S. Supreme Court. Therefore, the portions of the respondents' complaints that are 'inextricably intertwined' with the D.C. court's decision to deny their specific petitions must be dismissed for lack of jurisdiction. However, the promulgation of a general bar admission rule is a nonjudicial (legislative or administrative) act. Consequently, a federal district court has subject-matter jurisdiction to hear general, forward-looking constitutional challenges to the validity of the rule itself, such as claims that it creates an unconstitutional irrebuttable presumption or impermissibly delegates authority.
Dissenting - Justice Stevens
Yes, the District Court has subject-matter jurisdiction over all of the respondents' claims, including those challenging the application of the rule to their specific cases. The majority errs in two ways. First, the D.C. Court of Appeals' refusal to grant a waiver was not a judicial act; it was the administrative function of a licensing board exercising discretion, not adjudicating a claim of right. The respondents were requesting an exception, not demanding admission as a legal entitlement. Second, even if the denial were an adjudication, a suit in federal court alleging a constitutional violation is a permissible collateral attack under federal question jurisdiction, not an impermissible appellate review. The fact that the licensing body is a court should not immunize its allegedly unconstitutional actions from independent review in a federal district court.
Analysis:
This case, along with Rooker v. Fidelity Trust Co., establishes the Rooker-Feldman doctrine, a core principle of federal jurisdiction that prevents lower federal courts from sitting in direct review of state-court judgments. The decision creates a critical, though often difficult, distinction between impermissible claims seeking to undo a state judicial decision and permissible general or 'facial' challenges to the state rule that underpinned that decision. This doctrine forces litigants who lose in state court to seek review only in the U.S. Supreme Court, reinforcing principles of comity and finality. It has a significant impact on civil rights litigation, as plaintiffs must carefully frame their complaints to avoid appearing to appeal a state court loss, instead focusing on general constitutional infirmities of a statute or rule.
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