Home › Case briefs › Constitutional Law

Carter v. Burns

United States Court of Appeals for the Sixth Circuit · Constitutional Law

Constitutional LawRooker-Feldman doctrineSection 1983Facial vs. as-applied challenges42 U.S.C. § 1983Rooker-Feldmanstate-court judgmentsfacial challenge

Facts

Carter, a Tennessee prisoner proceeding pro se, sued fourteen Tennessee judges and justices in their official capacities under § 1983. He alleged that Tennessee statutes governing collateral review were unconstitutional, facially and/or as enforced and applied, because they deprived him of any opportunity to obtain judicial review of Brown-based constitutional claims challenging his convictions. Since State v. Brown, he had filed numerous habeas corpus and other post-conviction challenges in state court, and those claims were rejected as not cognizable in the proceedings he used or as time-barred. He sought a declaratory order that Tennessee is constitutionally required to provide an adequate corrective process for such claims.

Issue

Whether the Rooker-Feldman doctrine barred federal jurisdiction over Carter's § 1983 constitutional challenge to Tennessee collateral review statutes. More specifically, the court considered whether the doctrine barred both his facial challenge to those statutes and his as-applied challenge based on how Tennessee courts had denied review of his claims.

Rule

Under the Rooker-Feldman doctrine, federal district courts lack jurisdiction over cases brought by state-court losers complaining of injuries caused by state-court judgments and inviting federal district court review and rejection of those judgments. The doctrine applies only when the plaintiff complains of injury from the state-court judgment itself, and it does not bar a general facial challenge to the constitutionality of a state law as distinct from a challenge to that law's application in a particular state case.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Darius Cole is serving a sentence in Ohio. After Ohio courts repeatedly rejected his efforts to raise a new category of constitutional innocence claim, he files a § 1983 action in federal district court in Cleveland seeking a declaration that an Ohio post-conviction statute is facially unconstitutional because it never permits that category of claim to be heard in any case.

Is the federal district court barred by the Rooker-Feldman doctrine from hearing Darius's suit?

Explanation. Rooker-Feldman bars only cases in which a state-court loser complains of injuries caused by the state-court judgment itself and invites federal district court review and rejection of that judgment. A general facial attack on the constitutionality of a state collateral-review statute is not barred, even if the plaintiff previously litigated under that statute in state court. Here, Darius challenges the statute on its face, not the correctness of any particular Ohio ruling. (Derived from Carter v. Burns (n.d.).)