The Rooker-Feldman Doctrine: Toward a Workable Role

Abstract

The Rooker-Feldman doctrine is the product of two cases decided by the Supreme Court six decades apart: appropriately, Rooker v. Fidelity Trust Co.' and District of Columbia Court of Appeals v. Feldman.2 Stated in its simplest and most uncontroversial form, the Rooker-Feldman doctrine provides that federal courts other than the Supreme Court lack jurisdiction to hear appeals from state court decisions.3 This conclusion is based on inferences drawn from 28 U.S.C. ?? 1257 and 1331.4 In practice, lower federal courts are using Rooker-Feldman in a wide variety of circumstances to conclude that they are unable to hear cases