In my appellate practice, I have witnessed befuddlement over the Rooker-Feldman doctrine, which is based on two Supreme Court cases decided sixty years apart: 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 Rooker-Feldman doctrine expresses the unremarkable principle that Congress has not given district courts general appellate jurisdiction over state court judgments. And yet, as scholars point out, courts and litigants alike are prone to misconstruing Rooker-Feldman or confusing it with the law on abstention and preclusion.
In Evans v. Cordray (6th Cir., Case No. 09-3998) (PDF), the Sixth Circuit attempted to clarify the scope of the Rooker-Feldman doctrine when it reversed a district court’s decision to dismiss a claim regarding the constitutionality of Ohio’s “vexatious litigator” statute pursuant to Rooker-Feldman. The Evans case originated from a divorce proceeding brought by Charles Evans in the Franklin County, Ohio Court of Common Pleas, Domestic Relations Division. In a separate state court action, Evans filed an abuse of process claim against his estranged wife. She, in turn, filed a counterclaim asserting that Evans was a “vexatious litigator” under Ohio Revised Code § 2323.52. The state court dismissed Evans’s abuse of process claim, and held he was a vexatious litigator. It entered an order pursuant to § 2323.52 prohibiting Evans from instituting or continuing actions in Ohio state courts without first obtaining leave. The domestic relations court subsequently denied Evans’s motions to continue his divorce case because he failed to seek leave pursuant to the state court’s order under § 2323.52.
In response, Evans filed a lawsuit in the United States District Court for the Southern District of Ohio against the Ohio Attorney General, Richard Cordray, and the Franklin County Court of Common Pleas, claiming that § 2323.52 was unconstitutional as applied to him and other litigants in Ohio domestic relations cases because it allegedly deprived them of their constitutional right of access to the courts. The district court dismissed Evans’s case on the ground that it lacked subject matter jurisdiction pursuant to the Rooker-Feldman doctrine. The Sixth Circuit reversed.
In an opinion written by Judge Griffin, the Sixth Circuit began by explaining that the Rooker-Feldman does not bar a district court from exercising subject matter jurisdiction simply because a party attempts to litigate in federal court a matter previously litigated in state court. Rather, it applies only to the “narrow ground” of “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” As the Sixth Circuit explained, in determining whether Rooker-Feldman bars a claim, courts must look to the source of the injury that the plaintiff alleges in the federal complaint. If the source of the plaintiff’s injury is the state court judgment itself, then the Rooker-Feldman doctrine bars the federal claim. On the other hand, if there is some other source of injury, such as a third party’s actions, then the plaintiff asserts an independent claim.
Applying these principles, the Sixth Circuit observed that “[t]he problem with the district court’s analysis is that it determined the source of Evans’s injury without reference to his request for relief.” Evans was not seeking relief from the domestic relations court’s decisions to deny him leave to proceed, but instead was seeking injunctive relief against the Ohio Attorney General and the Franklin County Court of Common Pleas from applying Ohio’s vexatious litigator statute against him in his divorce case. He also was seeking “permanent injunctive declaratory relief where Ohio Revised Code 2323.52 is unconstitutional as it applies to litigants designated vexatious who presently are, or subsequently become, involved in cases of divorce and domestic relations.” Accordingly, the Sixth Circuit concluded that “the source of Evans’s injury is Ohio’s allegedly unconstitutional present and future enforcement of § 2323.52’s remedial provisions in divorce proceedings, not the domestic court’s prior interlocutory decisions denying him leave to proceed,” and thus Rooker-Feldman did not apply.
The Rooker-Feldman doctrine may not be the most glamorous topic in the legal world, but if you are confronted with Rooker-Feldman in one of your cases in the Sixth Circuit, the Evans opinion is an important read.
