Rooker v. Fidelity Trust Co.

Rooker v. Fidelity Trust Co.,263 U.S. 413 (1923), was a case in which theUnited States Supreme Courtenunciated a rule ofcivil procedurethat would eventually become known as theRooker-Feldmandoctrine(also named for the later case ofDistrict of Columbia Court of Appeals v. Feldman,460U.S.462 (1983). The doctrine holds that lowerUnited States federal courtsmay not sit in direct review of state court decisions.^[1]

Rooker v. Fidelity Trust Co.
Supreme Court of the United States
Submitted November 26, 1923 Decided December 10, 1923
Full case name	William Velpeau Rooker, et al. v. Fidelity Trust Company, et al.
Citations	263U.S.413(more) 44 S. Ct. 149; 68L. Ed.362; 1923U.S. LEXIS2824
Case history
Prior	Appeal from the District Court of the U.S. for the District of Indiana
Subsequent	None
Holding
Congress has not given the lower federal courts appellate jurisdiction over judgments rendered by the courts of the states.
Court membership
Chief Justice William H. Taft Associate Justices Joseph McKenna·Oliver W. Holmes Jr. Willis Van Devanter·James C. McReynolds Louis Brandeis·George Sutherland Pierce Butler·Edward T. Sanford
Case opinion
Majority	Van Devanter, joined byunanimous
Laws applied
§ 238 of the Judicial Code

Background

The case originated inIndiana,where a judgment had been entered against theplaintiff,Rooker by an Indiana state court. The judgment was affirmed by theIndiana Supreme Court,and the plaintiff was denied review by theUnited States Supreme Court.

The plaintiff then filed a claim in theUnited States district courtin Indiana, seeking to overturn the judgment of the Indiana Supreme Court on constitutional grounds. The district court dismissed the claim for lack ofjurisdiction,and the plaintiff again appealed to the United States Supreme Court.

Issue

The issue in this case was whether the United States district court had properly dismissed the claim for lack of jurisdiction.

Result

TheTaft Court

The United States Supreme Court, in an opinion byJustice Van Devanter,affirmed the dismissal of the claim by the United States district court. The Court noted that, for the district court to have heard the case would have been an exercise ofappellate jurisdiction;but theU.S. Congresshas only granted the district courtsoriginal jurisdictionto hear cases arising under the Constitution and laws of the United States, meaning that they can only hear claims that were initially brought in or removed to the district court.

The Court noted that the Indiana state court had jurisdiction over the parties and the claims, provided due process, and adjudicated the issues, and that its decisions had been affirmed by the Indiana Supreme Court. Even if all of the Indiana courts came to the wrong conclusions, the only avenue of appeal left to the plaintiff was to the United States Supreme Court - for Congress had authorized no other court to hear appeals of state court decisions.

Later developments

This case laid the groundwork for the current understanding that the decisions of state courts can not be challenged in federal courts (other than the Supreme Court) unless Congress has enacted legislation that specifically authorized such relief. An example of legislation that has been interpreted to this effect is 28U.S.C.§ 2254, which authorizes federal courts to grant writs ofhabeas corpus.Another example of an explicit legislative exception to this doctrine was the statute passed by Congress to permit federal courts to review the decisions ofFloridacourts in theTerri Schiavocase.

See also

• List of United States Supreme Court cases, volume 263

External links

• ^263U.S.413(Text of the opinion on Findlaw.com)