## Facts

- Matthew F. Hale graduated from law school, passed the Illinois bar exam, and applied for admission to the Illinois bar.
- Illinois requires applicants to prove “good moral character and fitness,” evaluated in the first instance by the Committee on Character and Fitness, which operates under the authority of the Illinois Supreme Court.
- Hale publicly advocated racist and antisemitic views and led a white supremacist organization; the Committee investigated these activities when assessing his character and fitness.
- The Committee concluded Hale failed to meet his burden to prove the requisite character and fitness and denied certification (Dec. 16, 1998); the denial was affirmed within the admissions process (June 30, 1999).
- Hale petitioned the Illinois Supreme Court to review the denial and raised constitutional objections, including that the denial rested on his beliefs and advocacy in violation of the First Amendment; the Illinois Supreme Court denied review.
- Hale sought certiorari in the U.S. Supreme Court; certiorari was denied.
- Hale then filed suit in federal district court against the Committee, the Board of Admissions, and related officials, asserting federal constitutional claims and effectively seeking relief from the denial of admission.
- The federal district court dismissed for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine and also relied on preclusion grounds; Hale appealed.

## Issues

1. Whether Rooker–Feldman deprived the federal district court of subject-matter jurisdiction because the federal suit functioned as a de facto appeal from a final state-court decision denying bar admission.
2. Whether Hale’s federal constitutional claims were “inextricably intertwined” with the state-court decision such that adjudicating them would require reviewing and rejecting that decision.
3. Whether Hale’s claims could be treated as a general challenge to bar-admission rules rather than a challenge to the specific denial in his case.

## Decision

- The Seventh Circuit affirmed the dismissal for lack of subject-matter jurisdiction.
- The court held that the Illinois Supreme Court’s action on Hale’s petition constituted a final judicial decision for Rooker–Feldman purposes.
- Because Hale had an opportunity to present his constitutional objections in the state proceedings, federal district court review was barred.
- The court declined to reach the merits of Hale’s First Amendment and other constitutional claims.

## Legal Principles

- Lower federal courts lack jurisdiction to review or set aside state-court judgments; only the U.S. Supreme Court may review such decisions through certiorari.
- When a state supreme court has rendered a final decision on a bar-admission application, a subsequent federal suit seeking relief from that denial is barred as a de facto appeal.
- Federal constitutional claims are barred when they are “inextricably intertwined” with the state judgment—i.e., they would succeed only if the federal court effectively invalidated the state-court decision.
- A general, prospective challenge to the constitutionality of bar-admission rules may be cognizable in federal court, but claims aimed at overturning a particular admissions outcome fall within Rooker–Feldman’s jurisdictional bar.

## Conclusion

The Seventh Circuit held that federal courts could not hear Hale’s constitutional attack on Illinois’s denial of his bar admission because the Illinois Supreme Court’s final decision ended the matter for lower federal courts, and Hale’s federal claims would have required review and rejection of that state-court judgment.


Hale v. Comm. on Character & Fitness for the State of Ill., 335 F.3d 678 (7th Cir. 2003)