Rooker v. Fidelity Trust Co.
44 S. Ct. 149, 263 U.S. 413, 1923 U.S. LEXIS 2824 (1924)
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Rule of Law:
Federal district courts lack subject-matter jurisdiction to review and reverse judgments issued by state courts, even when those judgments are alleged to violate federal constitutional rights, as such review constitutes an impermissible exercise of appellate jurisdiction reserved exclusively for the U.S. Supreme Court.
Facts:
- Plaintiffs (Rooker) were parties in litigation in an Indiana state circuit court, where a judgment was rendered against them.
- The Indiana Supreme Court affirmed this judgment, giving effect to a state statute that Rooker alleged conflicted with the Contract Clause, Due Process, and Equal Protection clauses of the Fourteenth Amendment, and did not give effect to a prior state supreme court decision (the "law of the case").
- Rooker had previously attempted to have the U.S. Supreme Court review the state court's judgment by writ of error, but that attempt failed because the record did not disclose a question warranting such a review.
- Rooker alleged that the Indiana Supreme Court judgment of affirmance was void because one of the participating judges had a disqualifying interest, having been designated as an executor and trustee in a will involving stock in corporations holding property under trusts similar to the one in question.
Procedural Posture:
- Plaintiffs (Rooker) filed a bill in equity in a U.S. District Court, seeking to have the Indiana state court judgment declared null and void and to obtain other dependent relief.
- The U.S. District Court dismissed the bill, concluding it lacked jurisdiction over the suit.
- Plaintiffs appealed this dismissal directly to the U.S. Supreme Court under § 238 of the Judicial Code.
- Appellees (Fidelity Trust Co.) moved the U.S. Supreme Court to dismiss the appeal or, in the alternative, affirm the District Court's decree.
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Issue:
Does a federal district court have jurisdiction to entertain a bill in equity seeking to declare a state court judgment null and void on the grounds that it was rendered in contravention of the U.S. Constitution?
Opinions:
Majority - Mr. Justice Van Devanter
No, a federal district court does not have jurisdiction to entertain a bill in equity seeking to declare a state court judgment null and void, even if based on alleged constitutional errors, because this would constitute an improper exercise of appellate jurisdiction. The Court affirmed the District Court's dismissal, holding that federal district courts possess strictly original jurisdiction and cannot function as appellate tribunals to review state court decisions. If constitutional questions arose in the state courts, it was their province and duty to decide them; and their decision, whether right or wrong, was an exercise of jurisdiction. A wrong decision does not make the judgment void, but merely leaves it open to reversal or modification in an appropriate and timely appellate proceeding. Under congressional legislation, only the U.S. Supreme Court could entertain a proceeding to reverse or modify a state supreme court judgment for errors of a federal character (Judicial Code, § 237). Allowing a district court to do so would be an exercise of appellate jurisdiction, which federal district courts lack (Judicial Code, § 24). Furthermore, the period for direct appellate review had expired, and a litigant cannot be permitted to do indirectly what they can no longer do directly. The Court found the allegations regarding the judge's disqualification to be unsubstantiated and not sufficient to change the nature of the bill or confer jurisdiction.
Analysis:
This case, along with D.C. Court of Appeals v. Feldman, established what is now known as the 'Rooker-Feldman doctrine.' It is a narrow jurisdictional doctrine that prevents lower federal courts from reviewing or reversing state court judgments. The doctrine distinguishes between a collateral attack on a state court judgment, which is prohibited, and a general federal question claim that happens to have been previously litigated in state court, which may be permissible. The Rooker-Feldman doctrine primarily applies when a party is essentially appealing a state court loss to a federal district court, rather than bringing an independent claim that merely challenges the same underlying conduct disputed in state court. This doctrine limits federal judicial power by upholding the finality of state court judgments and preserving the U.S. Supreme Court's exclusive appellate jurisdiction over state supreme courts on federal questions.
