Lead Opinion
The Rooker-Feldman doctrine prevents the lower federal courts from exercising jurisdiction over cases brought by “state-court losers” challenging “state-court judgments rendered before the district court proceedings commenced.” Exxon Mobil Corp. v. Saudi Basic Industries Corp.,
I
This is the latest of several rounds of litigation involving the State of Colorado’s congressional redistricting after the 2000 census, under which the State gained a seat in the House of Representatives. Lance v. Davidson,
The General Assembly passed its own redistricting plan in the spring of 2003, prompting further litigation — this time about which electoral map was to govern, the legislature’s or the courts’. Two suits were filed seeking to enjoin the legislature’s plan: an original action in the Colorado Supreme Court by the state attorney general seeking to require the secretary of state to use the court-ordered plan, and a similar action brought in a lower state court by several proponents of the court-ordered plan.
The second suit Was removed to federal court by the defendants on the basis of the plaintiffs’ federal-law claims. See Keller v. Davidson,
Finally, this suit: Before the dismissal in Keller, several Colorado citizens unhappy with Salazar filed an action in the District Court seeking to require the secretary of state to use the legislature’s plan.
The three-judge District Court ruled that under the Rooker-Feldman doctrine, it had no jurisdiction to hear the Elections Clause claim.
The plaintiffs appealed. See 28 U. S. C. § 1253. We now note jurisdiction, and address whether the Rooker-Feldman
II
This Court is vested, under 28 U. S. C. § 1257, with jurisdiction over appeals from final state-court judgments. We have held that this grant of jurisdiction is exclusive: “Review of such judgments may be had only in this Court.” District of Columbia Court of Appeals v. Feldman,
The Rooker-Feldman doctrine takes its name from the only two cases in which we have applied this rule to find that a Federal District Court lacked jurisdiction. In Rooker, a party who had lost in the Indiana Supreme Court, and failed to obtain review in this Court, filed an action in Federal District Court challenging the constitutionality of the state-court judgment. We viewed the action as tantamount to an appeal of the Indiana Supreme Court decision, over which only this Court had jurisdiction, and said that the “aggrieved litigant cannot be permitted to do indirectly what he no longer can do directly.”
In Exxon Mobil, decided last Term, we warned that the lower courts have at times extended Rooker-Feldman “far beyond the contours of the Rooker and Feldman cases, overriding Congress’ conferral of federal-court jurisdiction concurrent with jurisdiction exercised by state courts, and superseding the ordinary application of preclusion law pursuant to 28 U. S. C. § 1738.”
Although we have never addressed the precise question before us, we have held Rooker-Feldman inapplicable where the party against whom the doctrine is invoked was not a party to the underlying state-court proceeding. See De Grandy, supra, at 1006. In De Grandy, the State of Florida sought, using Rooker-Feldman, to prevent the United States from bringing a challenge under §2 of the Voting Rights Act of 1965 to the reapportionment of state electoral districts. The Florida Supreme Court, in an action initiated by the
In the case before us, the plaintiffs were plainly not parties to the underlying state-court proceeding in Salazar. Salazar was an action brought by the state attorney general against the secretary of state, in which the Colorado General Assembly intervened.
Although the District Court recognized the “general rule” that “Rooker-Feldman may not be invoked against a federal-court plaintiff who was not actually a party to the prior state-court judgment,” 379 P. Supp. 2d, at 1123, it nevertheless followed Tenth Circuit precedent in allowing application of Rooker-Feldman against parties who were in privity with a party to the earlier state-court action,
A more expansive Rooker-Feldman rule would tend to supplant Congress’ mandate, under the Full Faith and Credit Act, 28 U. S. C. § 1738, that federal courts “ ‘give the same preclusive effect to state court judgments that those judgments would be given in the courts of the State from which the judgments emerged.’” Baker v. General Motors Corp.,
The judgment of the District Court is vacated, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
Notes
Although the secretary of state defended the legislature’s plan in Salazar, following that decision she agreed to defend the court-ordered plan in this litigation and to allow the state attorney general to represent her.
In holding that Rooker-Feldman does not bar the plaintiffs here from proceeding, we need not address whether there are any circumstances, however limited, in which Rooker-Feldman may be applied against a party not named in an earlier state proceeding — e. g., where an estate takes a de facto appeal in a district court of an earlier state decision involving the decedent.
Our holding also disposes of the claim, which the District Court did not reach, that plaintiffs were barred by Rooker-Feldman because they were in privity with the secretary of state, the other losing party in People ex rel. Salazar v. Davidson,
Dissenting Opinion
dissenting.
Rooker and Feldman are strange bedfellows. Rooker, a unanimous, three-page opinion written by Justice Van Devanter in 1923, correctly applied the simple legal proposition that only this Court may exercise appellate jurisdiction over state-court judgments. See Rooker v. Fidelity Trust Co.,
My disagreement with the majority arises not from what it actually decides, but from what it fails to address. Even though the District Court mistakenly believed it had no jurisdiction to hear this matter, its judgment dismissing the cause with prejudice was correct and should be affirmed. See Lance v. Davidson,
Appellants’ spurious Petition Clause claim was also properly dismissed by the District Court. See
For the foregoing reasons I respectfully dissent.
See, e. g., Comment, Collateral Estoppel and the Rooker-Feldman Doctrine: The Problematic Effect These Preclusion and Jurisdictional Principles Have on Bankruptcy Law, 21 Emory Bankr. Dev. J. 579 (2005); Comment, The Rooker-Feldman Doctrine: Toward a Workable Role, 149 U. Pa. L. Rev. 1555 (2001); Proctor, Wirth, & Spencer, Rooker-Feldman and the Jurisdictional Quandary, 2 Fla. Coastal L. J. 113 (2000); Rowley, Tenth Circuit Survey, The Rooker-Feldman Doctrine: A Mere Superfluous Nuance or a Vital Civil Procedure Doctrine? An Analysis of the Tenth Circuit’s Decision in Johnson v. Rodrigues, 78 Denver U. L. Rev. 321 (2000); Symposium, The Rooker-Feldman Doctrine, 74 Notre Dame L. Rev. 1081 (1999); Pfander, An Intermediate Solution to State Sovereign Immunity: Federal Appellate Court Review of State-Court Judgments After Semi
Concurrence Opinion
concurring.
I agree in full with the Court’s correction of the District Court’s Rooker-Feldman error, and therefore join the Court’s opinion. Although Justice Stevens has persuasively urged that issue preclusion warrants affirmance, see post, at 468-469 (dissenting opinion), that question of Colorado law seems to me best left for full airing and decision on remand.
