Paul Hulsey v. Frank Cisa, 947 F.3d 246

In 2006 Lawton Limehouse Sr. and Jr. sued attorney Paul Hulsey for defamation in South Carolina state court; Hulsey removed, the cases were remanded, and Hulsey failed to answer, producing default damage trials where he was denied discovery and to present evidence.
The South Carolina Supreme Court vacated the default verdicts in Limehouse v. Hulsey and ordered proceedings to recommence because of a remand-procedure defect; it nevertheless agreed the trial court properly limited Hulsey after default.
On remand, Hulsey obtained evidence of a large tax levy on the Limehouses’ businesses, defended at a merits trial (winning at least one jury verdict), and later settled both cases in 2016.
In 2017 Hulsey filed a federal suit alleging the Limehouses, their attorneys, and witnesses ran sham defamation suits, committed perjury, fabricated evidence, and concealed the tax levy as part of a RICO/fraud scheme.
The district court dismissed for lack of jurisdiction under the Rooker–Feldman doctrine, concluding Hulsey’s suit effectively attacked state-court rulings denying him discovery in the default trials.
The Fourth Circuit reversed and remanded, holding Rooker–Feldman did not bar Hulsey’s independent federal claims and declining to resolve alternative grounds for dismissal not decided below.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker–Feldman bars the federal suit	Hulsey: claims are independent federal RICO/fraud claims against third-party misconduct, not an appeal of a state judgment	Defendants: the suit effectively attacks state-court rulings (discovery denials), so Rooker–Feldman applies	Rooker–Feldman does not apply; claims are independent and not an improper appeal of a state judgment
Whether Hulsey is a "state-court loser" for Rooker–Feldman purposes	Hulsey: he did not lose the underlying suits (won at retrial and later settled); interlocutory discovery orders were vacated	Defendants: denial of discovery in default trials amounts to an adverse state-court decision	Not a state-court loser; the relevant orders were not final judgments that produced the claimed injury
Whether the federal claims are "inextricably intertwined" with the state judgments	Hulsey: injuries flowed from defendants’ alleged fraud, not from the state-court judgments	Defendants: the fraud claims rehash or rely on issues litigated in state court and thus are intertwined	Not inextricably intertwined; plaintiff seeks redress for independent injuries caused by defendants’ misconduct
Whether alternative defenses (preclusion, other grounds) support dismissal	Hulsey: (argues merits)	Defendants: raise multiple alternative bases for affirmance	Fourth Circuit declined to decide unaddressed alternative grounds and remanded for the district court to consider them first

Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (district courts lack appellate jurisdiction to review state-court judgments)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (federal district courts cannot review final state-court judicial decisions)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (Rooker–Feldman confined to cases brought by state-court losers seeking review of state judgments)
Lance v. Dennis, 546 U.S. 459 (U.S. 2006) (Rooker–Feldman applies to appeals by state-court losers)
Skinner v. Switzer, 562 U.S. 521 (U.S. 2011) (doctrine limited to cases seeking review and rejection of state judgments)
Davani v. Virginia Dep’t of Transp., 434 F.3d 712 (4th Cir. 2006) (reviewing Rooker–Feldman dismissal de novo)
Thana v. Bd. of License Comm’rs, 827 F.3d 314 (4th Cir. 2016) (distinguishing actions that sidetrack state-court appeal process)
Hoblock v. Albany Cty. Bd. of Elections, 422 F.3d 77 (2d Cir. 2005) (injury may be enabled by but not produced by a state-court decision)
Limehouse v. Hulsey, 744 S.E.2d 566 (S.C. 2013) (South Carolina Supreme Court vacated default verdicts and ordered proceedings to recommence)