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Law School Case Brief

Rooker v. Fid. Tr. Co. - 263 U.S. 413, 44 S. Ct. 149 (1923)

Rule:

If constitutional questions stated in a bill actually arise in a state court case, it is the province and duty of the state courts to decide them; and their decision, whether right or wrong, is an exercise of jurisdiction. If a state court's decision is wrong, that does not make the judgment void, but merely leaves it open to reversal or modification in an appropriate and timely appellate proceeding. Unless and until so reversed or modified, it is an effective and conclusive adjudication.

Facts:

The present case is a bill in equity to have a judgment of a circuit court in Indiana, which was affirmed by the Supreme Court of Indiana, declared null and void, and to obtain other relief dependent on that outcome. According to the appellants, they resorted to filing the bill in equity to the federal district court because the judgment of the state court was rendered and affirmed in contravention of the contract clause of the Constitution of the United States and the due process of law and equal protection clauses of the Fourteenth Amendment. The District Court dismissed the bill, holding that the suit was not within its jurisdiction. The appellees sought review in the United States Supreme Court.

Issue:

Did the federal court have the jurisdiction to try the case at hand?

Answer:

No.

Conclusion:

The United States Supreme Court held that the federal district court had no jurisdiction to entertain what was essentially an appeal from a state court. It affirmatively appeared from the bill that the judgment was rendered in a case in which the state court had jurisdiction over the parties and subject matter, that a full hearing was held, that the state court's judgment was responsive to the issues, and that the judgment was affirmed on appeal to the state's highest court. Thus, there was an effective and conclusive adjudication. The Court noted that the bill was merely an attempt to collaterally attack the judgment for alleged errors of law committed in the state court. However, after the time in which to appeal elapsed, appellants could not be permitted to do indirectly what they no longer could do directly.

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