The Lawletter Vol 39 No 7
Anne Hemenway, Senior Attorney, National Legal Research Group
The Rooker-Feldman doctrine, developed by the U.S. Supreme Court, provides that because the jurisdiction of the federal district courts "is strictly original," Rooker v. Fid. Trust Co., 263 U.S. 413, 416 (1923), a federal district court "has no authority to review final judgments of a state court in judicial proceedings[,]" D.C. Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983). The doctrine is consistent with, and serves to implement, 28 U.S.C. § 1257, which allows only the U.S. Supreme Court to review final judgments and decrees rendered by the highest court of a state.
In Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005), the Supreme Court, in an attempt to simplify the application of the Rooker-Feldman doctrine, instead severely narrowed the scope of the doctrine to only those situations in which the loser in a state court judgment rendered before the district court proceedings commenced invites a federal district court to review and reject the state court judgment. This decision, along with Lance v. Dennis, 546 U.S. 459 (2007), was intended to return the Rooker-Feldman doctrine to its original setting. Yet the impact of Exxon Mobil may have narrowed the application of the doctrine too much to preclude litigants from enforcing 28 U.S.C. § 1257 against parties other than the losing party in a state court case.
Rather than applying the specific limitations in Exxon Mobil, federal appellate courts have since established their own tests to determine whether the Rooker-Feldman doctrine applies. In Great Western Mining & Mineral Co. v. Fox Rothschild, LLP, 615 F.3d 159 (3d Cir. 2010), the court developed a four-part test to implement the doctrine in light of Exxon Mobil. Courts also continue to define the terms "inextricably intertwined" and "independent claim" and to determine whether these terms, used in Exxon Mobil, enlarge the core holdings of Rooker or Feldman. See Truong v. Bank of Am., N.A., 717 F.3d 377 (5th Cir. 2013).
