Cooper v. Ramos

Under the Rooker-Feldman doctrine, 28 U.S.C. § 1257 vests the power to hear direct appeals from state court judgments to the United States Supreme Court, not to federal district courts. Although the doctrine does not preclude a plaintiff from bringing an “independent claim” that was not the subject of a previous state court judgment, if subsequent claims are “inextricabl[y] intertwined” with a claim the court does not have jurisdiction to hear, the court will also be barred from hearing those subsequent claims.

After the Court determined that it had jurisdiction to consider the district court’s ruling, the Court affirmed the district court’s dismissal of a complaint brought by Kevin Cooper, a convicted murderer who challenged a state court’s denial of his request to obtain additional DNA testing pursuant to a state statute. Cooper sought post-conviction DNA testing of three pieces of evidence under California Penal Code § 1405. The Superior Court denied Cooper’s motion because he had not produced any evidence to support his theory of tampering. The Court determined that the essence of his claim was barred under the Rooker-Feldman doctrine because it is “at least in part a forbidden de facto appeal of a state court judgment.” Cooper’s second and third claims of conspiracy to prevent him from obtaining DNA testing and conspiracy to deny fair investigation and conviction are also barred under the doctrine. They are “inextricabl[y] intertwined” with the Superior Court’s order denying his request for DNA testing, which is exactly the type of horizontal review of state court decisions that the Rooker-Feldman doctrine bars. The Court also held that the district court did not err in implicitly denying Cooper’s request to amend the complaint because his claims were collaterally estopped. Therefore, amendment would not save any of his claims. AFFIRMED.