Rooker-Feldman doctrine

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Under the Rooker-Feldman doctrine, federal district courts lack subject-matter jurisdiction over any action that "in essence, would be an attempt to obtain direct review of the [state court's judicial] decision in the lower federal courts." ASARCO Inc. v. Kadish, 490 U.S. 605, 622-23 (1989).

Put another way, the Rooker-Feldman doctrine provides that no federal district or appellate court has jurisdiction to review state court judgments. Sheehan v. Marr, 207 F.3d 35, 39-40 (1st Cir. 2000); see District of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462 (1983); Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923). For federal claims not presented in state court, Rooker-Feldman "forecloses lower federal court jurisdiction over claims that are 'inextricably intertwined' with the claims adjudicated in a state court." Sheehan, 207 F.3d at 39-40. A federal claim is "inextricably intertwined with the state-court judgment if the federal claim succeeds only to the extent that the state court wrongly decided the issues before it." Hill v. Conway, 193 F.3d 33, 39 (1st Cir. 1999). The logic of this rule stems from the proposition that if a federal court were able to grant relief from the state-court judgment, it would be "difficult to conceive the federal proceeding as, in substance, anything other than a prohibited appeal of the state-court judgment." Hill, 193 F.3d at 39.

The U.S. Supreme Court has held Rooker-Feldman to be inapplicable where the party against whom the doctrine is invoked was not a party to the underlying state-court proceeding. See De Grandy, supra, at 1006, 114 S. Ct. 2647, 129 L. Ed. 2d 775.

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