Background
Donald Wenger, proceeding pro se, appealed from a district court judgment that dismissed his action sua sponte. The underlying action arose out of state court proceedings.
The court’s reasoning
The court reviewed the dismissal de novo and affirmed. It held that the district court properly dismissed the action under the Rooker-Feldman doctrine because Wenger’s claims amounted to a forbidden de facto appeal of a prior state court judgment or were inextricably intertwined with that judgment. The court noted that while Rooker-Feldman does not bar a collateral challenge to a state court judgment in a case within federal exclusive jurisdiction, Wenger failed to establish that this exception applied.
What it means going forward
Federal courts will dismiss cases that function as appeals of state court judgments unless the plaintiff can show the state judgment falls within a category of exclusive federal jurisdiction.
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