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Bankruptcy | Case Law | Rooker Feldman Doctrine
ROOKER-FELDMAN DOCTRINE
Reusser v. Wachovia Bank, N.A., 525 F.3d 855 (9th Cir. 2008)
Debtors’ claims under 42 U.S.C. § 1983 brought in United States District Court constituted
a de facto appeal of a state court default judgment, and were barred by the Rooker-Feldman
doctrine.
Vacation Village, Inc. v. Clark County, Nev, 497 F.3d 902 (9th Cir. 2007)
Doctrine only applies where the plaintiff asserts legal errors by the state court and seeks
relief from a state court judgment. Doctrine did not apply in this case, because there was no state
court judgment.
In re Lopez, 367 B.R. 99 (9th Cir. BAP 2007)
1. The Rooker-Feldman doctrine does not override or supplant the issue and claim
preclusion doctrines; 2. Issue preclusion applied in this § 523(a)(6) action, where the state court
found that the debtor willfully and maliciously misappropriated customer lists.
In re Harbin, 486 F.3d 510, 519 (9th Cir. 2007)
Doctrine did not prevent a bankruptcy court from considering the affect of a state court
appeal on the debtor’s chapter 11 plan.
In re Williams, 280 B.R. 857 (9th Cir. B.A.P. 2002)
Under Rooker-Feldman doctrine, state court decision was binding on bankruptcy case even
though decision was still on appeal and not final for claim-preclusion purposes under California
law.
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