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...