Rooker Feldman Doctrine

ROOKER-FELDMAN DOCTRINE

Reusser v. Wachovia Bank, N.A., 525 F.3d 855 (9th Cir. 2008)

Debtors’ claims under 42 U.S.C. § 1983 brought in United States District Court constituted

a de facto appeal of a state court default judgment, and were barred by the Rooker-Feldman

doctrine.

Vacation Village, Inc. v. Clark County, Nev, 497 F.3d 902 (9th Cir. 2007)

Doctrine only applies where the plaintiff asserts legal errors by the state court and seeks

relief from a state court judgment. Doctrine did not apply in this case, because there was no state

court judgment.

In re Lopez, 367 B.R. 99 (9th Cir. BAP 2007)

1. The Rooker-Feldman doctrine does not override or supplant the issue and claim

preclusion doctrines; 2. Issue preclusion applied in this § 523(a)(6) action, where the state court

found that the debtor willfully and maliciously misappropriated customer lists.

In re Harbin, 486 F.3d 510, 519 (9th Cir. 2007)

Doctrine did not prevent a bankruptcy court from considering the affect of a state court

appeal on the debtor’s chapter 11 plan.

In re Williams, 280 B.R. 857 (9th Cir. B.A.P. 2002)

Under Rooker-Feldman doctrine, state court decision was binding on bankruptcy case even

though decision was still on appeal and not final for claim-preclusion purposes under California

law.

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