Applying the Rooker-Feldman abstention doctrine in an appeal of a state court decision to a federal district court

Petitioner, proceeding pro se, appealed a federal district court dismissing his federal action challenging a New York State court’s issuance of a divorce decree that awarded Petitioner’s former spouse a share of his “military pension.” 

In so doing, the federal district court rejected Petitioner's argument that the New York State Supreme Court decision violated the Uniformed Services Former Spouses’ Protection Act, [see 10 U.S.C. §1408] when it treated his military benefits as marital property that could be distributed to his ex-spouse in the court's adjudication his New York State divorce proceeding.*

Reviewing the district court’s dismissal of Petitioner's action and considering the Rooker-Feldman Abstention Doctrine, the Circuit Court explained Rooker-Feldman strips a district court of subject-matter jurisdiction "where a party in effect seeks to take an appeal of an unfavorable state-court decision to a lower federal court” and applies where: 

(1) "the federal-court plaintiff lost in state court;

(2)"the plaintiff complains of injuries caused by a state court judgment;

(3) "the plaintiff invites review and rejection of that judgment; and

(4) "the state judgment was rendered before the district court proceedings commenced."

Noting that each of these four element had been satisfied in this instance and Petitioner "does not argue that these four elements of the Rooker-Feldman doctrine have not been met" but, rather, argued that the Rooker-Feldman abstention "simply does not apply to his case because the state court judgment violated the Uniformed Services Former Spouses’ Protection Act." 

In effect, Petitioner contended his "invocation of a federal statute is enough to overcome the doctrine", which the Circuit Court explained if that were so, then the doctrine itself would be a nullity, since virtually every plaintiff in a Rooker-Feldman-style case is claiming that "the state court judgment violated his federal rights."

In the words of the Circuit Court, this "is precisely what the Rooker-Feldman doctrine prohibits, and [Petitioner] has failed to show why his case – invoking the Uniformed Services Former Spouses’ Protection Act – falls outside the doctrine or the [United States] Supreme Court precedent surrounding it."

Although Petitioner contended that the federal district court confused his military pension for his “Veteran’s Administration Disability Compensation, Social Security Disability Insurance Benefits, Inheritance, and Estate Funds”, the Circuit Court of Appeal opined that "Whatever the merits of that argument, the Rooker-Feldman doctrine bars lower federal courts from overruling a state court judgment like the one issued here."

Instead, said the court, such arguments must be made "to the state courts in the first instance, and then to the Supreme Court of the United States on direct appeal from the state’s court of last resort".  Citing Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 and other decisions, the Second Circuit Court of Appeals noted that “[a]fter state court proceedings are completed, Rooker-Feldman means that a party cannot seek review in a federal district court”.

* The Federal District Court had dismissed Petitioner’s complaint with prejudice,  concluding that his suit was barred by the Rooker-Feldman abstention doctrine and the Eleventh Amendment to the United States Constitution.

Click HERE to access the Circuit Court of Appeals, Second Circuit's decision posted on the Internet.