The Rooker-Feldman Doctrine was addressed in a case posted here on July 19, 2011, "Foreclosure Lawsuits Problems Attempt Overwhelming Courts: No. 2, With Solutions". In basic and simple terms, the "Doctrine" is a short-hand reference to the simple concept that there is only one Federal Court in which appellate review is possible of Judgments issued by State Courts, and that one Court is the United States Supreme Court.
In an interesting twist of this simple concept, some Courts are acknowledging its existence as a "Doctrine" even in cases in which it has no place.
Instead, calling the concept a "Doctrine" assumes that this simple concept has something like a life of its own. In his decision in the case of Download Tri-State Truck Insurance, Ltd. v. First Nat'l Bank of Wamego (D. Kan. Case No. 09.4158, Memorandum and Order Filed August 3, 2011) PUBLIC ACCESS, also published as 2011 WL 3349153 (D. Kan. August 3, 2011)(authorized password required to access Westlaw), a Senior District Judge raised the Rooker-Feldman Doctrine on his own when the parties did not raise it. The Federal Judge determined that the Doctrine did not apply in that case because the "Doctrine" does not apply to nonparties. Tri-State Truck Insurance, Ltd. v. First National Bank of Wamego, 2011 WL 3349153 at *5 & n.9.
Sometimes giving a simple concept a name like "Doctrine" almost infuses it with an imperative to pay attention to it even when the concept clearly has no place in the case at hand. Parenthetically, the decision in that case involved competing Motions for Summary Judgment, one by the Plaintiffs in particular for a Declaratory Judgment and another by the Bank on its Claim for Breach of Contract. The Plaintiffs' Motion was granted, and the Court directed the Clerk to enter a specified Declaratory Judgment including that the Plaintiffs did not breach their contractual obligations at issue in the case. The Federal Court denied the Bank's Motion.
All without dismissing a Federal Case based only on the fact that it involved previously entered State Court Judgments.
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