Rooker v. Fidelity Trust Co.

Supreme Court of the United States · 1923 · Federal Courts

Federal CourtsRooker doctrinestate-court judgmentsappellate jurisdictionoriginal jurisdictionDistrict Court jurisdictionfederal review of state judgmentsconstitutional claims

Facts

The same parties who had litigated in Indiana state court brought a federal equity suit to nullify the state-court judgment and obtain related relief. They alleged the state judgment and affirmance violated the Contract Clause and the Due Process and Equal Protection Clauses by giving effect to a state statute allegedly inconsistent with those provisions and by failing to follow an earlier state supreme court decision in the same cause. The bill itself showed that the Indiana circuit court had jurisdiction over the subject matter and parties, that a full hearing occurred, that the judgment responded to the issues, and that the Indiana Supreme Court affirmed it. The bill also asserted that one state supreme court judge was disqualified by an interest arising from his designation in a will as executor and trustee, but the pleaded facts showed no disqualifying interest.

Issue

Whether a federal District Court has jurisdiction to entertain a suit seeking to declare a final state-court judgment null and void and thereby reverse or modify it on the ground that the state courts committed constitutional or other legal errors. Also, whether the allegation that one state supreme court judge was disqualified changed the nature of the suit or created federal jurisdiction.

Rule

Where a state court had jurisdiction over the subject matter and parties and rendered a judgment after full hearing that was responsive to the issues, alleged constitutional or legal errors in that judgment do not make it void. Under Congress's jurisdictional scheme, no federal court other than the Supreme Court may entertain a proceeding to reverse or modify such a state-court judgment; District Courts possess strictly original, not appellate, jurisdiction, and a litigant may not do indirectly after the review period has expired what he can no longer do directly.

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In Columbus, Ohio, Nora Benton lost a contract dispute in Ohio state court after a full bench trial. The Ohio Supreme Court affirmed, and Nora then filed suit in federal district court against Liam Voss asking the court to declare the state judgment void because the state courts misapplied the Contract Clause and deprived her of due process.

Should the federal district court exercise jurisdiction?

Explanation. When a state court had jurisdiction over the subject matter and the parties, held a full hearing, and entered a judgment responsive to the issues, alleged constitutional error does not make the judgment void. A federal district court cannot entertain a proceeding whose object is to reverse or modify that judgment; that would be appellate review, and district courts have strictly original jurisdiction. (Derived from Rooker v. Fidelity Trust Co. (1923).)