ARTICLE: The Fraud Exception to the Rooker-Feldman Doctrine: How It Almost Wasn't (and Probably Shouldn't Be) Skip over navigation
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Copyright (c) 2011 Federal Magistrate Judges Association 
Federal Courts Law Review

ARTICLE: The Fraud Exception to the Rooker-Feldman Doctrine: How It Almost Wasn't (and Probably Shouldn't Be)

November, 2011

Federal Courts Law Review

2011 Fed. Cts. L. Rev. 139


Steven N. Baker *



The Rooker-Feldman doctrine is familiar to any practitioner or academic who regularly deals with federal-court jurisdiction. The basic idea is simple: the lower federal courts do not have jurisdiction to reverse or modify a state-court judgment. 1 Although this limitation was arguably implicit in the Judiciary Act of 1789, 2 it was not until 1923 that the United States Supreme Court made it an explicit part of federal court jurisprudence in Rooker v. Fidelity Trust Co. 3 The Supreme Court revisited this limitation sixty years later in D.C. Court of Appeals v. Feldman, 4 giving the doctrine the second half of its name. The lower federal courts took Rooker and Feldman and ran, 5 declining to exercise jurisdiction over a great many cases, including some where the plaintiff's challenge, although arguably related to a state-court judgment, did not necessarily seek to have it reversed or modified. In 2005, the Supreme Court again revisited the Rooker-Feldman doctrine in Exxon Mobil Corp. v. Saudi Basic Industries Corp., reining in the lower courts' excessive jurisdictional declination and limiting the doctrine's application to "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." 6

At first glance, one would not think Rooker-Feldman, a jurisdictional doctrine, would be subject to a number of exceptions. 7 After all, jurisdictional inquiries are as close to being absolute as one gets in the ...
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