Ep. 62 - T. M. v University of Md. Medical System Corporation: The Rooker-Feldman Doctrine

Part A.

Federal district courts generally lack any power to review directly cases from state courts.

The Supreme Court is the only federal court with appellate jurisdiction to review state court judgments, and that jurisdiction extends only to final judgments or decrees rendered by the highest court of a state in which a decision could be had.

28 U.S.C.

Section 1257a.

In Rooker v. Fidelity Trust Co., the court held that a federal district court lacked jurisdiction to declare a state court judgment null and void because doing so would be an exercise of appellate jurisdiction which only the Supreme Court possesses, and the jurisdiction possessed by the district courts is strictly original.

In District of Columbia Court of Appeals v. Feldman, the court held that a federal district court lacked jurisdiction to review a final judicial determination of the D.C. High Court because such review can be obtained only in the Supreme Court under Section 1257.

Rooker and Feldman rest on two closely related bases of reasoning.

First, when plaintiffs essentially invite federal courts of first instance to review and reverse unfavorable state court judgments, they are seeking an exercise of appellate jurisdiction.

Second, such appellate jurisdiction to reverse or modify a state court judgment is lodged by 28 U.S.C.

§ 1257 exclusively in the Supreme Court.

This court has since refused to expand the Rooker-Feldman Doctrine but has also reaffirmed its rule in the narrow ground it occupies.

Part B. T. M.'s case falls within the narrow ground occupied by Rooker Feldman.

because she is complaining of injuries caused by and seeking relief from the state court judgment itself, arguing that the consent order violates her federal and state due process rights and was entered into under duress.

The consent order was rendered 10 days before TM commenced this federal lawsuit, and she plainly seeks review and rejection of the consent order by asking the district court to declare it unconstitutional, unenforceable, and void ab initio and enjoin its enforcement.

Part C.

The court rejects TM's argument that Brooker-Feldman should apply only to final judgments rendered by the highest court of a state in which a decision could be had, i.e., the kinds of judgments that strictly fall within this court's jurisdiction under 28 U.S.C.

§ 1257.

Section 1.

TM's theory cannot be squared with the court's precedence.

TM reads the court's prior Rooker-Feldman cases not to evince any concern about district courts exercising what amounts to appellate jurisdiction over state court judgments, but instead as relying on a strict negative inference from Section 1257.

When this court has jurisdiction over a state court judgment, district courts must not.

but this court's precedents plainly adopted a more functional view of what constitutes original and appellate jurisdiction under Section 1331.

In Rooker, nothing in the court's reasoning suggested the outcome would have been different had the judgment still been on appeal.

The court held that seeking to reverse or modify the state court judgment would be an exercise of appellate jurisdiction, which the district court lacks because it has strictly original jurisdiction.