4th Cir.

CAROL D. MOORE v. STEVE MANSBERY, Attorney; ALICE C. STUBBS, Attorney; THARRINGTON SMITH, LLP, Law firm

July 21, 2026 ·24-1992 ·Per Curiam ·Per Curiam · By Aisha Johnson

The Fourth Circuit affirmed a district court dismissal of a civil rights complaint based on the Rooker-Feldman doctrine.

Listen to this decision 0:00 / 0:53

Background

Carol D. Moore filed a civil rights action against attorneys and a law firm in the United States District Court for the Middle District of North Carolina. The district court accepted a magistrate judge’s recommendation and dismissed the complaint without prejudice.

The court’s reasoning

The appellate court reviewed the record and found no reversible error in the lower court’s application of the Rooker-Feldman doctrine to dismiss the case for lack of subject matter jurisdiction.

What it means going forward

Litigants cannot use federal courts to appeal state court judgments directly under Section 1983 when the Rooker-Feldman doctrine applies.