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Posted: December 29, 2014

Second Circuit Affirms Dismissal on Rooker-Feldman Grounds

On December 18, 2014, the Second Circuit issued a decision in Canning v. Administration for Children’s Services, Queens, 13-4047-CV, affirming the dismissal of a lawsuit in the EDNY for lack of subject matter jurisdiction based on the Rooker-Feldman doctrine.

In Canning, the plaintiffs brought an action in the EDNY challenging the constitutionality of a decision in an action brought against them by the New York State Administration for Children’s Services in Queens County Family Court. The Second Circuit affirmed the EDNY’s dismissal of the EDNY action for lack of subject matter jurisdiction, explaining:

Defendants’ motion to dismiss argued, in part, that the District Court lacked jurisdiction pursuant to the Rooker-Feldman doctrine. This doctrine is a bundle of rules named after the Supreme Court’s decisions in Rooker v. Fidelity Trust Co., and D.C. Court of Appeals v. Feldman, limiting federal appellate jurisdiction over state court decisions to the United States Supreme Court. This doctrine stands for the proposition that federal courts lack jurisdiction over 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. The doctrine bars suit only if the federal court plaintiff (1) lost in state court, (2) seeks redress for injuries caused by a state court judgment, (3) invites district court review and rejection of that judgment, and (4) files suit after judgment has been entered in the parallel state proceedings.

Here, all four requirements of the Rooker-Feldman doctrine were met. The Cannings lost custody of their children pursuant to a July 2012 state court order, and they sought damages and injunctive relief arising from that proceeding in their January 2013 federal court action. They invite review and rejection of the state court judgment by arguing, inter alia, that it violated their inalienable right to raise their children, was procured through the use of unconstitutional procedures, and was obtained without meeting the sufficient burden of proof. The Cannings cannot escape the Rooker-Feldman doctrine by couching their claims in constitutional violations, even if those legal theories were not raised in the prior state court proceedings. Thus, the District Court properly granted the defendants’ motion to dismiss for lack of jurisdiction.

(Internal quotations and citations omitted).

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