Tuesday, June 17, 2003

Rooker-Feldman doctrine bars consideration of state physician's employment claims in federal court

In Horner v. Department of Mental Health, Judge Michael of the W.D. Va. affirmed the magistrate judge's conclusion that plaintiff's claims regarding his employment as a physician at the Western State mental hospital were barred by the Rooker-Feldman doctrine, since he had filed a grievance challenging his discharge and appealed the decision of the hearing officer to the state circuit court, which also had ruled against him.

The Rooker-Feldman doctrine, to the extent I understand it, bars the use of the federal courts as a forum for appealing adverse rulings in state. Or, as Judge Michael wrote, "The Rooker-Feldman doctrine generally bars federal district
courts from 'sit[ting] in direct review of state court decisions.' District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 483 n. 16 (1983); Rooker v. Fidelity Trust Co., 263 U.S. 413, 415-416 (1923). 'Rather, jurisdiction to review such decisions lies exclusively with superior state courts and, ultimately, the United States Supreme Court.' Phyler v. Moore, 129 F.3d 728, 731 (4th Cir. 1997)."

I'm not sure whether this ruling doesn't go a step beyond the law as I understood it, but it is a sort of catch-22 aspect to the relationship between filing a lawsuit and raising constitutional issues - the plaintiff can't waive available procedural remedies and then complain about the lack of due process, but also the plaintiff who pursues a grievance might not have access to the full panoply of remedies that are available in a section 1983, and the decisionmaker for the grievance hearing might not be as competent and unbiased.

The Fourth Circuit also applied the Rooker-Feldman doctrine today in Ford v. Georgetown County Water and Sewer District, a per curiam decision by the panel of Judges Niemeyer and Luttig and Senior Judge Hamilton, in which the Court concluded that the federal court claims clearly sought review of state court proceedings, and noted in a footnote, that to the extent they were not the same, the additional issues could have been raised in state court and were therefore barred by the doctrine of res judicata.

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