## Facts

- Rooker litigated against Fidelity Trust Co. in an Indiana state circuit court.
- The state trial court had jurisdiction over the parties and subject matter, conducted a full hearing, and entered judgment against Rooker.
- The Indiana Supreme Court affirmed the judgment.
- Rooker attempted to obtain U.S. Supreme Court review by writ of error, but review failed because the record did not present a reviewable federal question.
- Rooker then filed a federal equity action in the U.S. District Court for the District of Indiana seeking to have the state judgment declared null and void and to obtain relief dependent on that invalidation.
- The federal bill alleged the state judgment violated the Contract Clause and the Due Process and Equal Protection Clauses because it applied an allegedly unconstitutional state statute and disregarded a prior Indiana Supreme Court decision claimed to control.
- The district court dismissed for lack of jurisdiction.
- Rooker appealed directly to the U.S. Supreme Court under § 238 of the Judicial Code; the defendants moved to dismiss the appeal or to affirm.

## Issues

1. Whether the appeal to the U.S. Supreme Court fell within § 238 of the Judicial Code.
2. Whether a federal district court has jurisdiction to set aside a final state-court judgment on the theory that the state courts committed constitutional error.

## Decision

- The Court held the appeal was within § 238 and denied the motion to dismiss.
- The Court affirmed the district court’s dismissal for lack of jurisdiction.
- The Court held that a federal district court may not entertain a suit by a losing state-court party seeking to have the state judgment declared void based on alleged constitutional errors.
- The Court treated the federal action as an impermissible attempt to obtain appellate review of a state judgment.
- The Court rejected the contention that alleged constitutional mistakes rendered the state judgment void where the state courts had jurisdiction and power to render the judgment.
- The Court also concluded that the asserted basis for state-judge disqualification did not establish a jurisdictional defect in the state proceedings.

## Legal Principles

- Federal district courts exercise original jurisdiction and have no statutory authority to function as appellate tribunals over state-court judgments.
- When a state trial court with jurisdiction renders judgment after due hearing and the state’s highest court affirms, federal correction of constitutional error is available only through the U.S. Supreme Court’s appellate review as provided by Congress.
- A state-court decision on constitutional questions, even if incorrect, is an exercise of jurisdiction and does not make the judgment void; it remains effective unless reversed or modified on direct review.
- A party may not reframe alleged legal error in a state judgment as a voidness theory to obtain collateral relief in federal district court.

## Conclusion

The Supreme Court held that lower federal courts lack jurisdiction to invalidate final state-court judgments for alleged constitutional error; such review is reserved to the U.S. Supreme Court through the statutory appellate path, not collateral federal district court litigation.


Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923)