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I. THE ROOKER-FELDMAN DOCTRINE

At its most basic, the Rooker-Feldman doctrine, named after the two cases from which it sprung,¹² is the principle that lower federal courts do not have jurisdiction to review state court judgments.¹³ It is based on the congressional grant, in 28 U.S.C. § 1257,¹⁴ of appellate [*pg 645] jurisdiction over state court judgments to the United States Supreme Court and the grant of original jurisdiction over certain suits to United States district courts.¹⁵ Read together, these statutes indicate that the Supreme Court’s appellate jurisdiction over state court judgments is exclusive and the jurisdiction¹⁶ of the federal district courts is purely original.¹⁷ In addition to these statutory bases, prudential considerations such as judicial federalism¹⁸ and system consistency¹⁹ also underlie the doctrine. Because these limits are statutory and prudential rather than constitutional, Congress can and has made exceptions to the doctrine, most notably in granting district courts jurisdiction over the habeas corpus petitions of state prisoners.²⁰

Although the Supreme Court has never found a case to be barred by the Rooker-Feldman doctrine aside from the two for which it is named,²¹ lower federal courts regularly employ an expansive version of the doctrine to dismiss federal actions.²² Understanding the [*pg 646] cases that initially gave rise to the Rooker-Feldman doctrine is essential to recognizing its intended scope.

A. Rooker v. Fidelity Trust Co.

The plaintiffs in Rooker v. Fidelity Trust Co.²³ asked that the federal court declare null and void the judgment of an Indiana circuit court, which had been affirmed by the state’s supreme court; they also sought “to obtain other relief dependent on that outcome.”²⁴ The Rookers were unhappy with the state court decision in favor of Fidelity, and they believed that errors in the state court’s judgment were to blame. After the judgment, they filed suit in federal district court, claiming that the state court decision violated the Contracts Clause, due process, and equal protection in that it gave effect to a supposedly unconstitutional state statute and did not give effect to a prior decision by the Indiana Supreme Court, which was alleged to have become “the law of the case.”²⁵

The district court dismissed the case, finding it not to be within its jurisdiction as defined by Congress, and the United States Supreme Court agreed.²⁶ After first noting that the state court properly had jurisdiction over the case and that the plaintiffs had a full hearing there, the Court concluded:

If the constitutional questions stated in the bill [the federal suit] actually arose in the cause [the state suit], it was the province and duty of the state courts to decide them; and their decision, whether right or wrong, was an exercise of jurisdiction. If the decision was wrong, that did not make the judgment void, but merely left it open to reversal or modification in an appropriate and timely appellate proceeding.²⁷

[*pg 647]

The Court then emphasized that lower federal courts are not the “appropriate appellate proceeding” in which to correct state court errors.²⁸ No federal court other than the Supreme Court had been given authority by Congress to reverse or modify state court judgments, the Court held; to do so would be an exercise of appellate jurisdiction, and “[t]he jurisdiction possessed by the District Courts is strictly original.”²⁹

Rooker‘s holding, that federal district courts are not the correct place for parties to appeal issues decided against them in state court, is a narrow and uncontroversial principle.³⁰ After Rooker, lower federal courts applied this principle with regularity, usually to bar actions with facts closely analogous to those of Rooker itself.³¹ The Supreme Court cited Rooker only once, in passing,³² in the sixty years between the Rooker decision and its companion case, District of Columbia Court of Appeals v. Feldman.³³

The obama /holder clan has no jurisdiction to review or intervene with Senate Bill 1070 or the recent Alabama Anti Illegal Immigration Bill.  There for States courts and States Attorneys should simply ignore them for lack of standing.