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Law School Case Brief

D.C. Court of Appeals v. Feldman - 460 U.S. 462, 103 S. Ct. 1303 (1983)

Rule:

Lower federal courts possess no power whatever to sit in direct review of state court decisions. If the constitutional claims presented to a United States district court are inextricably intertwined with a state court's denial in a judicial proceeding of a particular plaintiff's application for admission to a state bar, then the district court is in essence being called upon to review the state-court decision. This the district court may not do. 

Facts:

Two bar applicants filed petitions in the state District of Columbia Court of Appeals asking for waivers of that court's District of Columbia bar admission rule requiring applicants to have graduated from an American Bar Association approved law school.The District of Columbia Court of Appeals issued per curiam orders denying the petitions. The applicants filed complaints in the United States District Court for the District of Columbia challenging the District of Columbia Court of Appeals' denial of their waiver petitions. The United States District Court for the District of Columbia dismissed the complaints on the ground that it lacked subject matter jurisdiction. The United States Court of Appeals for the District of Columbia Circuit, reversing the United States District Court, held that the District Court had jurisdiction to review the District of Columbia Court of Appeals' denial of the applicants' requests for waivers of the bar admission rule. The United States Supreme Court granted certiorari review.

Issue:

Do federal district courts have subject matter jurisdiction in challenges to state court decisions arising out of judicial proceedings?

Answer:

No

Conclusion:

The United States Supreme Court held that the admission proceedings before petitioner state appellate court were judicial in that they involved a claim of a present right to admission to the bar and a denial of that right, such that, as a determination from the highest court of the District of Columbia, the decision was only appealable to the United States Supreme Court. The Court also held, however, that to the extent respondents challenged the general constitutionality of D.C. Ct. App. R. 461(b)(3), which was used to deny their admissions to the bar, a district court could have subject matter jurisdiction over their complaint because no review of final state-court judgment was required. Accordingly, the judgment below was vacated and the case was remanded for further proceedings.

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