This paper discusses the evolution of the Rooker-Feldman doctrine, and its application in bankruptcy law.
The Rooker-Feldman doctrine arises from two Supreme Court decisions separated by sixty years. The gist of the doctrine is that lower federal courts do not have subject matter jurisdiction to review state court judgments. Review of state court judgments in the federal court system lies only with the United States Supreme Court. Rooker-Feldman, in essence, bars a party losing in state court from seeking what would be appellate review of the state judgment in a United States district court.
The Rooker-Feldman doctrine can be confusing as applied in the area of bankruptcy law. At this time, it has not been mentioned in any published opinions from the bankruptcy courts in Indiana, however it has the potential to be an important weapon in the arsenal of a bankruptcy court practitioner. The paper discusses in detail the application of the Rooker-Feldman doctrine in bankruptcy cases in other jurisdictions, and how it has evolved over the decades in recent case law.
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