“The Rooker-Feldman doctrine had been construed by some federal courts ‘to extend far beyond the contours of the Rooker and Feldman cases.’”

March 7th, 2011

In Skinner v. Switzer, Justice Ginsburg expressed some doubt as to how the lower courts apply the Rooker-Feldman doctrine.

As we explained in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280 (2005), the Rooker-Feldman doctrine has been applied by this Court only twice, i.e., only in the two cases from which the doctrine takes its name: first, Rooker v. Fidelity Trust Co., 263U. S. 413 (1923), then 60 years later, District of Columbia Court of Appeals v. Feldman, 460 U. S. 462 (1983). Both cases fit this pattern: The losing party in state court9 filed suit in a U. S. District Court after the state proceedingsended, complaining of an injury caused by the state-court judgment and seeking federal-court review and rejection of that judgment. Alleging federal-question jurisdiction, the plaintiffs in Rooker and Feldman asked the District Court to overturn the injurious state-court judgment. We held, in both cases, that the District Courts lacked subjectmatter jurisdiction over such claims, for 28 U. S. C. §1257“vests authority to review a state court’s judgment solelyin this Court.” See Exxon, 544 U. S., at 292.

We observed in Exxon that the Rooker-Feldman doctrine had been construed by some federal courts “to extend farbeyond the contours of the Rooker and Feldman cases.” Id., at 283. Emphasizing “the narrow ground” occupied bythe doctrine, id., at 284, we clarified in Exxon that Rooker-Feldman “is confined to cases of the kind from which the doctrine acquired its name: cases brought by state-courtlosers . . . inviting district court review and rejection of[the state court’s] judgments.” Ibid.

Skinner’s litigation, in light of Exxon, encounters no Rooker-Feldman shoal. “If a federal plaintiff ‘present[s][an] independent claim,’” it is not an impediment to the exercise of federal jurisdiction that the “same or a related question” was earlier aired between the parties in state court. id., at 292–293 (quoting GASH Assocs. v. Rosemont, 995 F. 2d 726, 728 (CA7 1993); first alteration in original); see In re Smith, 349 Fed. Appx. 12, 18 (CA6 2009) (Sutton, J., concurring in part and dissenting in part) (a defendant’s federal challenge to the adequacy of state-law procedures for postconviction DNA testing is not within the “limited grasp” of Rooker-Feldman).As earlier noted, see supra, at 7–8, Skinner does not challenge the adverse CCA decisions themselves; instead, he targets as unconstitutional the Texas statute theyauthoritatively construed. As the Court explained in Feldman, 460 U. S., at 487, and reiterated in Exxon, 544U. S., at 286, a state-court decision is not reviewable bylower federal courts, but a statute or rule governing the decision may be challenged in a federal action.10 Skinner’s federal case falls within the latter category. There was, therefore, no lack of subject-matter jurisdiction over Skinner’s federal suit.11


Continuing its comments in Exxon, we may see in the near future a pairing back of the Rooker-Feldman doctrine.