Seventh Circuit Applies What Is Left Of The Rooker-Feldman Doctrine

Not much is left of the holdings of Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), and of the eponymous Rooker-Feldman doctrine, but what remains was the subject of the Seventh Circuit's recent decision in Harold v. Steel, No. 14-1875 (7th Cir. Dec. 11, 2014), written by Judge Easterbrook.

The Rooker-Feldman doctrine stands for the principle that the only federal court that can review judgments entered by a state court in civil litigation is the Supreme Court of the United States. Lower federal courts lack subject-matter jurisdiction "when the state court's judgment is the source of the injury of which plaintiffs complain in federal court." Slip op. 3.

Harold began with a small-claims judgment in Marion County, Indiana. Harold had agreed to the judgment's entry nearly two decades ago, but failed to pay, which caused the judgment's (alleged) creditor, Steel, to secure a garnishment order from the Indiana court. Harold challenged that order, contending that "Steel had misrepresented the judgment creditor's identity . . . and did not represent the only entity authorized to enforce the judgment." Id. at 2. He lost in the Indiana court, but then filed his federal suit under 15 U.S.C. § 1692e of the Fair Debt Collection Practices Act, alleging that Steel had made false statements. The district court dismissed his federal suit under Rooker-Feldman.

Harold faced an uphill battle from the outset. The Seventh Circuit already had held, in Epps v. Creditnet, Inc., 320 F.3d 756 (7th Cir. 2003), that the "doctrine bars federal suits seeking to recover on a theory that a debt collector made false statements during state litigation." Slip op. 2.

Harold persevered, nevertheless, arguing that Rooker-Feldman did not apply to interlocutory decisions in state courts, that his claim was independent of the state court's decision, and that the doctrine did not apply to the procedures that state courts use or the evidence that state judges consider. The court noted that the circuits are split on the first issue, though it's hard to see why an interlocutory decision should be...