Rooker-Feldman Doctrine Is Jurisdictional and Must Be Considered before Addressing Merits

Cook v. Baca, 2013 U.S. App. LEXIS 4783(10th Cir. Mar. 7, 2013):

In its dismissal order, the district court declined to consider whether the Rooker-Feldman doctrine applied. Rooker-Feldman, however, "concerns a district court's subject-matter jurisdiction," Lance v. Coffman, 549 U.S. 437, 439 n* (2007), and must therefore be considered "before proceeding to the merits," id. at 439.

"Rooker-Feldman is a jurisdictional prohibition on lower federal courts exercising appellate jurisdiction over state-court judgments." Campbell v. City of Spencer, 682 F.3d 1278, 1281 (10th Cir. 2012). It applies to "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments." Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). Rooker-Feldman prohibits "review of the proceedings already conducted by the [state court] tribunal to determine whether it reached its result in accordance with law." Campbell, 682 F.3d at 1283 (internal quotation marks omitted).

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