Johnson v. De Grandy

In Johnson v. De Grandy, 512 U.S. 997, 1006 (1994), the U.S. Supreme Court held that Rooker-Feldman doctrine did not bar the United States from bringing its own action in federal court because the United States "was not a party in the state court," and "was in no position to ask this Court to review the state court's judgment and has not directly attacked it in this proceeding."

In this case the State of Florida sought, using Rooker-Feldman, to prevent the United States from bringing a challenge under § 2 of the Voting Rights Act of 1965 to the reapportionment of state electoral districts. The Florida Supreme Court, in an action initiated by the state attorney general, had already declared the law valid under state and federal law.