## Facts

- Gary Facio was sued in Utah state court by Collection Management Agency, Inc. to collect on a dishonored check.
- Facio was properly served but did not answer, believing his earlier payment resolved the matter.
- The Utah state court entered a default judgment against Facio.
- Facio moved to set aside the default judgment under Utah Rules of Civil Procedure 55(c) and 60(b), but the motion did not show a “meritorious defense,” a prerequisite under Utah law as applied by Utah courts.
- The state trial judge, Maurice Jones, denied relief from the default judgment.
- The judgment was satisfied through garnishment of Facio’s wages and bank account.
- Facio then filed a federal action under 42 U.S.C. § 1983 against Judge Jones and the collection agency, seeking declaratory relief invalidating Utah’s “meritorious defense” requirement and relief tied to the garnishment.
- The federal district court declared the Utah requirement unconstitutional and awarded costs and attorney’s fees under 42 U.S.C. § 1988; Facio also sought fees against the judge.

## Issues

1. Whether the federal district court had subject-matter jurisdiction over a § 1983 action where the requested relief would effectively negate a final state-court default judgment.
2. Whether Facio’s constitutional challenge and related relief were “inextricably intertwined” with the state-court judgment, making the federal suit a prohibited de facto appeal under the Rooker–Feldman doctrine.

## Decision

- The Tenth Circuit held the federal district court lacked subject-matter jurisdiction under the Rooker–Feldman doctrine.
- The court concluded Facio’s claimed injury and requested declaratory relief depended on undermining the state default judgment and the denial of his motion to vacate.
- The court vacated the district court’s judgment, including the constitutional ruling and the fee award.
- The case was remanded with instructions to dismiss for lack of jurisdiction.
- Because jurisdiction was lacking, the court did not reach the cross-appeal concerning attorney’s fees against the state judge.

## Legal Principles

- Lower federal courts lack jurisdiction to review, reverse, or effectively modify final state-court judgments; review lies only in the U.S. Supreme Court under 28 U.S.C. § 1257.
- Rooker–Feldman bars not only direct federal appeals of state judgments but also claims “inextricably intertwined” with such judgments, where federal relief would functionally invalidate the state result.
- A plaintiff cannot obtain federal declaratory or injunctive relief when standing and redressability depend on first upsetting an existing state-court judgment; such a claim is jurisdictionally barred rather than subject to discretionary abstention.

## Conclusion

The Tenth Circuit vacated the district court’s merits and fee rulings and ordered dismissal because the § 1983 action was, in practical effect, an attempt to obtain lower federal-court review of a final Utah default judgment and related proceedings, which Rooker–Feldman forbids.


Facio v. Jones, 929 F.2d 541 (10th Cir. 1991)