Michelle R. Gilbank v. Wood County Department of Human Services, et al.

Deployed in “tens of thousands of circuit and district court decisions,” App.15a, the Rooker-Feldman doctrine stops lower federal courts from exercising appellate jurisdiction over state judgments. Along with other elements required for the doctrine to apply, claims are barred if they invite “district court review and rejection” of a state judgment. Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). The circuits have split over the meaning of “review and rejection.” Some circuits read “review and rejection” broadly to mean disagreement, thus extending Rooker-Feldman to bar federal claims for damages even where the state judgment neither awarded nor denied damages—meaning the federal claim could never vacate or modify the state judgment’s relief. Other circuits read “review and rejection” narrowly, properly limiting Rooker-Feldman to bar federal claims seeking appellate relief that would vacate or modify the state judgment. A fractured en banc Seventh Circuit divided along the existing split. Despite disagreeing on substance, “[a]ll members of the en banc court agree[d]” there is “a need for the Supreme Court to clarify application of the doctrine.” App.3a. The question presented is: Should the Rooker-Feldman doctrine—which stops lower federal courts from exercising appellate jurisdiction over state judgments—extend to bar federal claims for damages where the state judgment neither awarded nor denied damages, meaning the federal claim could not vacate or modify the judgment’s relief?