In English v. Crochet, No. 25-30074 (5th Cir. Oct. 8, 2025), a Fifth Circuit panel partially reverses a Fed. R. Civ. P. 12(b)(6) dismissal of a diversity case, holding in relevant part that the tort suit is not blocked by the Rooker-Feldman doctrine even though it calls into doubt monetary sanctions entered by a state-courtContinue reading “Lawsuit Against Attorneys for Alleged Conduct During a State-Court Action Not Blocked by Rooker-Feldman Doctrine, Holds Fifth Circuit”
Tag Archives: Rooker-Feldman
State-Court Conspiracy Case Alleging Judicial Collusion with Defense Counsel Not Barred by Rooker-Feldman, Holds Eighth Circuit
In Sutter & Gillham PLLC v. Henry, No. 24-1071 (8th Cir. July 31, 2025), the Eighth Circuit reverses dismissal of a 42 U.S.C. § 1983 conspiracy action concerning a state-court judge, alleging collusion with defense counsel, and holds that the action does not fall within the Rooker-Feldman doctrine. “The alleged conspiracy grew out of anContinue reading “State-Court Conspiracy Case Alleging Judicial Collusion with Defense Counsel Not Barred by Rooker-Feldman, Holds Eighth Circuit”
Second Circuit Joins Other U.S. Courts of Appeals in Holding That Rooker-Feldman Does Not Apply to a State Case That Is Still on Appeal in State Court
In Hunter v. MacMahon, No. 21-1473 (2d Cir. July 21, 2023), the Second Circuit joins the First, Third, Fifth, Seventh, Eighth, Ninth, Tenth, and Eleventh Circuits in holding that the Rooker-Feldman doctrine does not extend to a federal lawsuit challenging the effects of a state-court judgment when a state-court appeal from that judgment remains pending.Continue reading “Second Circuit Joins Other U.S. Courts of Appeals in Holding That Rooker-Feldman Does Not Apply to a State Case That Is Still on Appeal in State Court”
Seventh Circuit Divides Over Whether There Is a “Corruption” Exception to the Rooker-Feldman Doctrine
In Hadzi-Tanovic v. Johnson, No. 21-3373 (7th Cir. Mar. 14, 2023), the Seventh Circuit overrules (over a two-judge dissent) prior panel decisions holding that a plaintiff can avoid the operation of the Rooker–Feldman doctrine by alleging that the state-court judgment was the product of corruption. “This case arises out of a custody dispute between plaintiffContinue reading “Seventh Circuit Divides Over Whether There Is a “Corruption” Exception to the Rooker-Feldman Doctrine”
Eleventh Circuit Criticizes Expansion of Rooker-Feldman by Lower Courts as “One-Size-Fits-All Preclusion Doctrine”
In Behr v. Campbell, No. 18-12842 (11th Cir. Aug. 12, 2021), the Eleventh Circuit reverses a sua sponte dismissal of a 30-count federal civil-rights complaint arising out of events from a state-court domestic relations dispute. “That kind of sweeping dismissal is not at all unusual—but it is also at odds with the Supreme Court’s clearlyContinue reading “Eleventh Circuit Criticizes Expansion of Rooker-Feldman by Lower Courts as “One-Size-Fits-All Preclusion Doctrine””
Split Sixth Circuit Panel Adheres to Prior Authority Applying Rooker-Feldman Doctrine to Interlocutory State-Court Order
In RLR Investments, LLC v. City of Pigeon Forge, Tenn., No. 20-6375 (6th Cir. July 13, 2021), a 2-1 panel holds that Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (Exxon), did not abrogate the circuit’s prior caselaw applying the Rooker-Feldman doctrine to state-court interlocutory orders. The Rooker-Feldman doctrine is aContinue reading “Split Sixth Circuit Panel Adheres to Prior Authority Applying Rooker-Feldman Doctrine to Interlocutory State-Court Order”
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