MBE Rules · Civil Procedure
Rooker-Feldman
Rooker-Feldman doctrine
The rule
Federal district courts lack jurisdiction over suits by state-court losers seeking review of state judgments; the doctrine is narrow and does not bar parallel claims of independent injury.
In plain English
The Rooker-Feldman doctrine prevents federal courts from reviewing decisions made by state courts. This means that if you lose in state court, you can't bring your case to federal court just to challenge that state court's ruling, but you can still bring separate claims that are not directly tied to the state court's decision.
Worked example
Alice loses a custody battle in state court and then tries to sue the state court judge in federal court, claiming the judge acted unfairly. Under the Rooker-Feldman doctrine, Alice's suit is dismissed because it seeks to review the state court's judgment. However, if Alice had instead sued for damages due to emotional distress caused by the custody battle, that claim could proceed in federal court.
Memory hook
No second chances in federal court for state losers!
The trap
Exams often present scenarios where students mistakenly believe they can appeal a state court decision in federal court, confusing it with the ability to bring independent claims. This can lead to incorrect answers if students don't recognize the distinction.
How examiners test it
Questions typically involve a state court decision followed by an attempt to bring a related claim in federal court, testing the student's understanding of the limitations imposed by Rooker-Feldman.
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