Norman Bartsch Herterich v. City and County of San Francisco, California, et al.

Petitioner filed two related complaints in federal district court. The district court dismissed both actions under the Rooker-Feldman doctrine, which provides that federal district courts lack jurisdiction over claims that have been finally decided by state courts. However, nothing in the record of either of Petitioner’s actions indicates that state courts decided any of the claims made in Petitioner’s complaints, and Petitioner asserted that state courts did not decide any of those claims. Yet a Ninth-Circuit panel nonetheless affirmed dismissal under Rooker-Feldman, holding that Petitioner’s actions were forbidden de facto appeals of unspecified prior state-court decisions and raised claims that were “inextricably intertwined” with those state-court decisions. The panel identified no state-court decisions and stated no fact about Petitioner’s actions other than that the actions alleged Constitutional violations “arising from” state-court cases and proceedings involving the estate of Petitioner’s father. The question presented is: Whether the Rooker-Feldman doctrine bars federal district-court jurisdiction over an action merely because the action alleges Constitutional violations “arising from” state-court proceedings, where the claims presented to the federal district court have not been adjudicated by state courts.