Document Type
Research Memorandum
Publication Date
2025
Abstract
(Excerpt)
An unfavorable state court judgment can lead to the losing party seeking a second bite at the apple in federal court, but the Rooker-Feldman doctrine blocks second attempts with limited exceptions. The jurisdictional doctrine is derived from two United States Supreme Court cases: Rooker v. Fidelity Trust Co. and District of Columbia Court of Appeals v. Feldman, where the collective holdings stand for the principle that a state court judgment is conclusive and that the lower federal courts lack jurisdiction to review such judgments. The Supreme Court is the only federal court authorized to review state court judgments.
The Rooker-Feldman doctrine serves as a jurisdictional barrier of entry into federal courts for bankruptcy litigation. The doctrine stays narrow enough not to preclude all state court appeals to the federal judiciary but assists in precluding parties seeking to relitigate the same arguments made in state court. This article addresses key case law in the context of bankruptcy surrounding the Rooker-Feldman doctrine. Part I explains potential limitations that arise from the strong preclusive effect that Rooker-Feldman can have on state court appeals. Part II outlines the federal exemptions and provision of title 11 of the United States Code (the "Bankruptcy Code") that allow for certain matters from state court to be litigated, while also enabling Rooker-Feldman to be a beneficial tool in precluding other state court issues that should be kept out of federal court. Finally, Part III examines a Fifth Circuit decision that presents a prime example of the doctrine in action.