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Federal Court
Jurisdiction
Rooker-Feldman
Court: U.S. 8th Circuit Court of Appeals Topic:
Civil Procedure, Civil Rights
Title of Case:
SIMES v.
HUCKABEE
Date: 01/13/04 Case Number: 02-3694, 02-3695
Summary:
The Rooker-Feldman doctrine "recognizes that, with the exception
of habeas
corpus petitions, lower federal courts lack subject matter jurisdiction over
challenges
to state court judgments." Id. The doctrine precludes district courts from
obtaining
jurisdiction both over the rare case styled as a direct appeal, Rooker v.
Fidelity Trust
Co., 263 U.S. 413, 416 (1923), as well as more common claims which are
"inextricably intertwined" with state court decisions. District of Columbia
Court of
Appeals v. Feldman, 460 U.S. 462, 483 (1983). The doctrine has its foundation in
the
Supreme Court's appellate jurisdiction statute, as well as a "concern[] with
federalism
and the proper delineation of the power of the lower federal courts." Lemonds,
222
F.3d at 495; 28 U.S.C. § 1257. . . .
The Rooker-Feldman doctrine does not bar federal claims brought in federal court when a state court previously presented with the same claims declined to reach their merits. Thus the district court erred in holding it lacked jurisdiction to consider claims by five members of a Quorum Court alleging that their incarceration, following their refusal to vote in favor of a certain county ordinance, violated their federal civil rights.
SIMES v. HUCKABEE- 02-3694, 02-3695-Rooker-Feldman Doctrine
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