Portfolio Recovery Associates, LLC v. Iris Pounds, et al.

Under the Rooker–Feldman doctrine, federal district courts lack jurisdiction over appeals from state-court judgments. However, many, if not all, states allow their trial courts to entertain independent actions that attack the validity of prior state-court judgments on various grounds, such as for lack of personal or subject-matter jurisdiction by the court that rendered the original judgments. These independent actions are original actions authorized by state law to be heard by state trial courts exercising original jurisdiction. Some pre- and post-Rooker decisions from this Court (and Rooker itself) suggest that a federal district court has jurisdiction to hear an independent action that attacks a prior state-court judgment. The federal courts of appeals, however, cannot agree on the propriety of a federal district court’s exercise of jurisdiction over independent actions. Some circuits have held that the Rooker–Feldman doctrine always bars these actions. Others have held that Rooker– Feldman does not apply when the state-court judgment was allegedly procured by fraud, or where the state court rendering the judgment lacked jurisdiction. Others have allowed federal district courts to entertain independent actions if a state trial court in the rendering forum could do so. The rules across the circuits are in conflict. See Sup. Ct. R. 10(a). Therefore, the question presented is: Does the Rooker–Feldman doctrine prohibit a federal district court from exercising jurisdiction over an independent action challenging the validity of a prior state-court judgment for lack of jurisdiction, when a state trial court could do so?