Seventh Circuit Review


Civil procedure involves a world of difficult obstacles and unknown traps if a person is not well- versed in the beast, and even for those people with professional expertise, the path is not always as transparent. One doctrine which seems to encompass this confusion well is the Rooker- Feldman doctrine. It is well established in the U.S. legal system that only the Supreme Court of the United States has appellate jurisdiction over final state court judgements and that any other federal court does not. As a direct result, one problem which arises quite frequently is when a party gets barred from raising a claim in federal court after previously filing a suit, alleging the same facts in state court but with different claims, that a court has already decided. The Rooker- Feldman doctrine, which is named after two landmark cases, contains the test that is used to determine whether that federal claim will be allowed to proceed in federal court or whether it will be barred. This note examines what exactly the Rooker-Feldman doctrine is with the guidance of Chief Judge Sykes’s concurrence in Andrade v. City of Hammond. This note will critique the "inextricably intertwined" approach to the Rooker-Feldman test and argue that it should not be the main tool in the analysis. This note also offers information as to why Rooker- Feldman gets confused with preclusion doctrine and how to separate the two. Finally, this note gives an example on the application of Rooker-Feldman when dealing with executive injuries in correlation with Rooker-Feldman analysis.