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Rooker-Feldman Doesn’t Bar Federal Jurisdiction over Independent Claim, Even If It Denies a Legal Conclusion State Court Reached — Plaintiff Must Seek Relief That Directly Attacks the Validity of a State Court Judgment

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Avdeef v. Royal Bank of Scotland, PLC, 2015 U.S. App. LEXIS 9498 (5th Cir. June 8, 2015):

1.  The Rooker-FeldmanDoctrine

The Rooker-Feldman doctrine occupies "narrow ground": it bars only "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). This Court has observed that "[a] state court judgment is attacked for purposes of Rooker-Feldman when the [federal] claims are 'inextricably intertwined' with a challenged state court judgment, or where the losing party in a state court action seeks what in substance would be appellate review of the state judgment." Weaver v. Tex. Capital Bank, N.A., 660 F.3d 900, 904 (5th Cir. 2011) (per curiam) (second alteration in original) (citations and internal [*15]  quotation marks omitted). However, Rooker-Feldman "does not preclude federal jurisdiction over an 'independent claim,' even 'one that denies a legal conclusion that a state court has reached.'" Id. (quoting Exxon, 544 U.S. at 293). Indeed, the doctrine "generally applies only where a plaintiff seeks relief that directly attacks the validity of an existing state court judgment." Id. If the plaintiff claims damages for injuries caused by the defendants' actions-even those occurring during litigation-rather than injuries arising from a state-court judgment itself, the federal suit is not barred by Rooker- Feldman.See Truong, 717 F.3d at 383.

We conclude that this case does not fall within the limited set of matters subject to Rooker-Feldman. Critically, Avdeef's complaint seeks relief other than review and reversal of the adverse state-court judgment: he requests damages for alleged constitutional violations and torts committed by the parties to the state-court action. This relief does not "directly attack[] the validity of an existing state court judgment." Weaver, 660 F.3d at 904. Relatedly, the source of Avdeef's injuries, according to his complaint, is not the state judgment [*16]  but the allegedly unlawful conduct of his adversaries. See Truong, 717 F.3d at 383. The mere fact that Avdeef's claims appear to be "inextricably intertwined" with the state-court judgment is not enough to invoke Rooker-Feldman's jurisdictional bar. See id. at 384-85. Thus, we turn to the district court's alternative grounds for dismissal.

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New York Attorneys JHA handles range the gamut of complex financial and commercial litigation and arbitration, including securities, RICO, corporate and contract disputes, credit default swaps, derivatives, and class, mass, and derivative actions. The firm also represents law firms in major disputes.
New York Attorneys JHA handles range the gamut of complex financial and commercial litigation and arbitration, including securities, RICO, corporate and contract disputes, credit default swaps, derivatives, and class, mass, and derivative actions. The firm also represents law firms in major disputes.

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