Federal courts are courts of limited jurisdiction. Marbury v. Madison (circa 1803) is perhaps the most famous example of this principle. But the limits of federal jurisdiction are regularly tested in our courts today. One recent Fourth Circuit decision is an example of the court exploring the role of federalism in federal jurisdiction, in what is known as the “Rooker-Feldman doctrine.”
The Rooker-Feldman doctrine prevents district courts from exercising jurisdiction over suits that are, in essence, appeals from state court judgments. The doctrine gets its name from Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983). In Rooker, the plaintiffs brought suit in federal district court alleging that the judgment against them in state court contravened the Constitution. The U.S. Supreme Court held that the district court could not entertain the claim, because it would “be an exercise of appellate jurisdiction[.]” Rooker, 236 U.S. at 416. The Supreme Court reiterated its holding in Feldman, stating “a United States District Court has no authority to review final judgments of a state court in judicial proceedings.” Feldman, 460 U.S. at 482.
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