Rooker Feldman Doctrine Bars Relitigating State Court Judgment in Federal Court

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Often, a dissatisfied litigant who lost in state court will try his or her luck in federal court in an attempt to escape the adverse state court ruling. Federal courts have limited subject matter jurisdiction, however, and will not serve as the appellate court to challenge issues previously adjudicated in state court. The Rooker-Feldman doctrine evolved to prevent this type of litigation tactic.

The Rooker-Feldman doctrine derives from two United States Supreme Court decisions, Rooker v. Fidelity Trust Co., 263 U.S. 413 1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983). The doctrine holds that United States federal courts (other than the U.S. Supreme Court) should not sit in direct review of state court decisions unless Congress has specifically authorized such relief. In short, federal courts below the Supreme Court must not become a court of appeals for state court decisions. The state court plaintiff has to find a state court remedy, or obtain relief from the U.S. Supreme Court.

Specifically, under the Rooker-Feldman doctrine, federal courts lack subject matter jurisdiction over complaints that "essentially invite[] federal courts of first instance to review and reverse unfavorable state-court judgments." See Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 283 (2005). "[A] claim is barred by Rooker-Feldman under two circumstances: first, if the federal claim was actually litigated in state court prior to the filing of the federal court action or, second, if the federal claim is inextricably intertwined with the state adjudication, meaning that federal relief can only be predicated upon a conviction that the state court was wrong." In re Knapper, 407 F.3d 573, 580 (3d Cir. 2005) (quotation omitted). "A federal claim is inextricably intertwined with an issue adjudicated in state court when: (1) the federal court must determine that the state court judgment was erroneously entered in order to grant the requested relief, or (2) the federal court must take an action that would negate the state court's judgment." Id. at 581 (quotation omitted).

Often, the Rooker-Feldman doctrine arises in connection with foreclosure proceedings where a homeowner looks to escape a foreclosure judgment by filing a kitchen-sink type complaint in federal court accusing the lender and/or its loan servicing agent of engaging in fraud. See e.g., Monclova v. US Bank N.A., No. 16-cv-3677, 2017 WL 118015, at *1 (3d Cir. Jan. 12, 2017). The Third Circuit has also expressly held that Rooker-Feldman applies to interlocutory orders of lower state courts. See Port Auth. Police Benevolent Ass'n, Inc. v. Port Auth. of N.Y. & N.J. Police Dep't, 973 F.2d 169, 177-78 (3d Cir. 1992).

Have you or your company been sued in the United States District Court for the District of New Jersey by the same liitgant whom you defeated in state court? If so, there may be a basis to dismiss the federal suit under the Rooker-Feldman doctrine.

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