Holly MacIntyre v. JPMorgan Chase Bank, N.A.

Whether a plaintiff in a diversity case who seeks monetary relief — for damages emanating from the defendant’s fraud in procuring a state-court judgment — thereby triggers application of the Rooker-Feldman doctrine because he is “necessarily” seeking federal review and rejection of the judgment itself, despite the fact the requested relief would leave the judgment in full force and effect.

Whether a federal court, which would have been sitting in diversity if not for a federal jurisdictional doctrine inapplicable in the state judiciary, may nonetheless invoke the state’s fee-shifting statute to award attorneys’ fees against the federal plaintiff, and may do so admittedly without ever having had subject matter jurisdiction.