Hooper v. Brnovich

The Rooker-Feldman doctrine is the principle that “a state-court decision is not reviewable by lower federal courts,” and federal district courts are prevented from exercising subject matter jurisdiction and the de facto equivalents of such appeals.

Petitioner alleged he was denied due process under the Eighth Amendment because the Arizona courts denied an injunction prohibiting his execution while seeking an injunction to permit him to conduct forensic testing. The district court denied relief and the Court found the district court lacked subject matter jurisdiction. The Rooker-Feldman doctrine is the principle that “a state-court decision is not reviewable by lower federal courts,” and federal district courts are prevented from exercising subject matter jurisdiction and the de facto equivalents of such appeals. If relief sought would effectively reverse the state court’s ruling then such relief is “inextricably intertwined” with the state court’s ruling and thus a de facto equivalent of an appeal. Petitioner’s claim was purely horizontal and he was challenging the particular outcome of his state case. VACATED and REMANDED with instructions to dismiss.