William Castro v. R. Fred Lewis, et al.

The Florida Supreme Court refused to address the merits of federal constitutional claims raised in Petitioner’s post-judgment motion to vacate arising from newly-discovered evidence of misconduct committed prior to that Court’s judgment permanently denying Petitioner admission to the Florida Bar. After Petitioner’s federal district court complaint alleging those claims pursuant to 42 U.S.C. § 1983 was dismissed for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine, the Eleventh Circuit affirmed the district court’s orders, concluding that Petitioner had a reasonable opportunity to raise those claims at the Florida Supreme Court, both before that Court issued its original judgment and subsequently in his post-appeal motion to vacate that judgment. Presently, the uneven application of the RookerFeldman doctrine by the lower federal courts undermines litigants’ due process right to have their federal constitutional claims adjudicated in either a state or federal forum. To resolve this conflict among the circuits, Petitioner presents the following issue for review: Whether the Rooker-Feldman doctrine bars subject-matter jurisdiction in a federal district court over federal constitutional claims filed pursuant to 42 U.S.C. § 1983 where: a) the underlying misconduct was unknown to Petitioner prior to the state court’s original judgment and did not figure in that state court’s decision; and b) Petitioner’s post-judgment motion to vacate raising those claims was not decided on the merits by the state court.