Rooker-Feldman Doctrine

The Rooker-Feldman doctrine is a jurisdictional rule that prevents federal courts from acting as appeals courts for state court decisions. If you lost in state court and then file a § 1983 case in federal court trying to undo that state court ruling, the federal court will dismiss your case for lack of jurisdiction.

This comes from two Supreme Court cases: Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983).

The Rule

Only the U.S. Supreme Court can review state court judgments. Federal district courts cannot. Period.

If your § 1983 claim is really just an argument that the state court got it wrong, the federal court has no jurisdiction to hear it.

When It Applies

Rooker-Feldman applies when all four conditions are met:

1. You lost in state court — There’s a state court judgment against you.
2. You’re asking the federal court to review that judgment — Your federal claims are “inextricably intertwined” with the state court decision.
3. The state proceedings ended before you filed in federal court — If the state case is still pending, Rooker-Feldman doesn’t apply (though Younger abstention might).
4. You were a party in the state case — or are in privity with someone who was.

Common Traps for Pro Se Plaintiffs

”The state judge was biased”

You believe the state court judge was corrupt, biased, or violated your due process rights during the state proceeding. You file a § 1983 case against the judge or the court system. This gets dismissed under Rooker-Feldman (and probably judicial immunity too). The proper remedy is a state court appeal, not a federal lawsuit.

”The prosecutor committed misconduct in my state case”

If you’re challenging the outcome of a state prosecution, that’s an appeal — not a § 1983 claim. If you were convicted, the Heck doctrine also blocks you.

”Child protective services took my kids based on lies”

State family court proceedings are among the most common Rooker-Feldman dismissals. If you’re challenging the custody decision itself, federal court can’t help. But if you’re challenging the conduct of the officials independent of the court ruling (e.g., social workers fabricated evidence, officers conducted an illegal search during the investigation), those claims may survive.

When It Doesn’t Apply

Rooker-Feldman is narrower than defendants often claim. It does not bar your case when:

You’re challenging conduct, not the judgment. If a police officer used excessive force during your arrest, that claim exists independently of whatever happened in the criminal case. You’re not asking the federal court to overturn the state court — you’re suing the officer for violating your rights. The state court judgment is irrelevant to the excessive force claim.

The state case is still pending. Rooker-Feldman only applies to final state court judgments. If the state case is ongoing, look at Younger abstention instead.

You weren’t a party. If you’re suing over police conduct that led to someone else’s state court case, Rooker-Feldman doesn’t apply to you.

Your claims are independent. The Supreme Court narrowed Rooker-Feldman significantly in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005). The doctrine only applies to cases “brought by state-court losers complaining of injuries caused by state-court judgments.” If your injury was caused by the defendant’s conduct — not by the court’s ruling — your claim survives.

How to Avoid It

Frame your claims around the officers’ conduct, not the court outcome. Don’t write your complaint as “the state court wrongly convicted me.” Write it as “Officer Smith used excessive force during the arrest” or “Detective Jones fabricated evidence in the affidavit.” The constitutional violation is the officer’s behavior, not the court’s decision.

Separate your claims clearly. If some claims challenge the state court judgment and others challenge independent conduct, the court may dismiss the judgment-related claims under Rooker-Feldman but keep the independent claims alive.

Appeal through the proper channels. If the state court actually got it wrong, appeal within the state court system. That’s what appellate courts are for. Save federal court for the constitutional violations committed by the government actors themselves.