The Supreme Court ruled 5-4 that federal district courts lack jurisdiction to review non-final judgments from state courts, rejecting an expansive interpretation of federal question jurisdiction under 28 U.S.C. § 1331.
The majority opinion, authored by Justice Samuel Alito, held that the Rooker-Feldman doctrine bars federal district courts from exercising appellate review over state court decisions that are not final. The doctrine, rooted in the Constitution's Article III limits on federal jurisdiction, prevents district courts from functioning as appellate courts over state proceedings.
The case centered on whether a party could bypass state appellate procedures by filing suit in federal district court under the federal question statute, which grants district courts jurisdiction over cases arising under the Constitution, federal laws, and treaties. The plaintiff sought federal review of a state court judgment that remained pending appeal in the state system.
Justice Alito emphasized that allowing federal district courts to review interlocutory state decisions would undermine the Rooker-Feldman doctrine and violate principles of federalism. The doctrine, established in Rooker v. Fidelity & Deposit Co. and District of Columbia Court of Appeals v. Feldman, prevents federal district courts from exercising appellate jurisdiction over final state court judgments. The Court extended this principle to non-final judgments.
The four dissenters, led by Justice Elena Kagan, argued the majority conflated subject matter jurisdiction with the Rooker-Feldman doctrine. Kagan contended that a genuine federal question could provide independent grounds for district court jurisdiction even if the state court had not finalized its judgment. She worried the ruling would foreclose federal forum access for litigants with meritorious federal claims.
The ruling strengthens federalism protections by preventing federal district courts from interfering with ongoing state proceedings. It creates a clear jurisdict