District of Columbia Court of Appeals v. Feldman

District of Columbia Court of Appeals v. Feldman
District of Columbia Court of Appeals v. Feldman
	Supreme Court of the United States
Argued December 8, 1982; Decided March 23, 1983
Full case name	District of Columbia Court of Appeals, et al. v. Feldman, et al.
Citations	460 U.S. 462 ( more ) 103 S. Ct. 1303; 75 L. Ed. 2d 206; 1983 U.S. LEXIS 150; 51 U.S.L.W. 4285
Case history
Prior	Hickey v. Dist. of Columbia Court of Appeals, 457 F. Supp. 584 (D.D.C. 1978); reversed sub. nom., Feldman v. Gardner, 661 F.2d 1295 (D.C. Cir. 1981)
Holding
	The Court held that lower United States federal courts may not sit in direct review of state court decisions, affirming the Rooker-Feldman doctrine.
Court membership
	Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White ; Thurgood Marshall · Harry Blackmun ; Lewis F. Powell Jr. · William Rehnquist ; John P. Stevens · Sandra Day O'Connor
Case opinions
Majority	Brennan, joined by Burger, White, Marshall, Blackmun, Powell, Rehnquist, O'Connor
Dissent	Stevens
Laws applied
	U.S. Const.

Last updated July 04, 2019

District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), was a case decided by the United States Supreme Court in which the Court enunciated a rule of civil procedure known as the Rooker-Feldman doctrine (also named for the earlier case of Rooker v. Fidelity Trust Co. ).^[1] The doctrine holds that lower United States federal courts may not sit in direct review of state court decisions.^[2]

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution. Executive acts can be struck down by the Court for violating either the Constitution or federal law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide non-justiciable political questions.

Civil procedure is the body of law that sets out the rules and standards that courts follow when adjudicating civil lawsuits. These rules govern how a lawsuit or case may be commenced; what kind of service of process is required; the types of pleadings or statements of case, motions or applications, and orders allowed in civil cases; the timing and manner of depositions and discovery or disclosure; the conduct of trials; the process for judgment; the process for post-trial procedures; various available remedies; and how the courts and clerks must function.

Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), was a case in which the United States Supreme Court enunciated a rule of civil procedure that would eventually become known as the Rooker-Feldman doctrine (also named for the later case of District of Columbia Court of Appeals v. Feldman, 460 U.S. 462. The doctrine holds that lower United States federal courts may not sit in direct review of state court decisions.

Facts

The U.S. Congress enacted several pieces of legislation with respect to Washington, D.C.'s local judicial system. One required final judgments from the District of Columbia Court of Appeals to be treated like final judgments from the high court of any state; another permitted that Court of Appeals to create rules governing the qualifications and admissions of attorneys to practice in the D.C. courts. The Court of Appeals then passed rules requiring applicants to the D.C. bar to have graduated from an ABA-accredited law school.

The United States Congress is the bicameral legislature of the Federal Government of the United States, and consists of two chambers: the House of Representatives and the Senate. The Congress meets in the United States Capitol in Washington, D.C.. Both senators and representatives are chosen through direct election, though vacancies in the Senate may be filled by a gubernatorial appointment. Congress has 535 voting members: 435 representatives and 100 senators. The House of Representatives has six non-voting members representing Puerto Rico, American Samoa, Guam, the Northern Mariana Islands, the U.S. Virgin Islands, and the District of Columbia in addition to its 435 voting members. Although they cannot vote in the full house, these members can address the house, sit and vote in congressional committees, and introduce legislation.

Washington, D.C., formally the District of Columbia and commonly referred to as Washington or D.C., is the capital of the United States. Founded after the American Revolution as the seat of government of the newly independent country, Washington was named after George Washington, the first president of the United States and a Founding Father. As the seat of the United States federal government and several international organizations, Washington is an important world political capital. The city is also one of the most visited cities in the world, with more than 20 million tourists annually.

The District of Columbia Court of Appeals is the highest court of the District of Columbia. Established in 1970, it is equivalent to a state supreme court, except that its authority is derived from the United States Congress rather than from the inherent sovereignty of the states. The court is located in the former District of Columbia City Hall building at Judiciary Square. The D.C. Court of Appeals should not be confused with the District's federal appellate court, the United States Court of Appeals for the District of Columbia Circuit. The D.C. Court of Appeals and the Superior Court of the District of Columbia comprise the District's local court system.

The plaintiffs - Feldman and Hickey - were practicing attorneys from other states, but neither had graduated from ABA-accredited law schools. Feldman had been admitted to the Virginia bar through an apprenticeship, and had been admitted to the Maryland bar through a waiver of their requirements, based on his personal experience. Feldman was denied admission by the Committee on Admissions of the District of Columbia Bar, so he sought a similar waiver of the D.C. rule, sending a letter to the D.C. Court of Appeals that suggested that their absolute prohibition of lawyers who had not attended certain schools was a violation of the Sherman Antitrust Act, and of the Fourteenth Amendment. Nevertheless, the D.C. Courts issued an opinion confirming that they would not waive their requirement. Hickey had a similar background, but did not suggest that the D.C. Court of Appeals was in violation of any laws.

American Bar Association association of lawyers

The American Bar Association (ABA), founded August 21, 1878, is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. The ABA's most important stated activities are the setting of academic standards for law schools, and the formulation of model ethical codes related to the legal profession. The ABA has 410,000 members. In 1979, half of all lawyers in the U.S. were members of the ABA; in 2019, 20% of the nation's lawyers were members. The organization's national headquarters are in Chicago, Illinois; it also maintains a significant branch office in Washington, D.C.

Virginia, officially the Commonwealth of Virginia, is a state in the Southeastern and Mid-Atlantic regions of the United States located between the Atlantic Coast and the Appalachian Mountains. The geography and climate of the Commonwealth are shaped by the Blue Ridge Mountains and the Chesapeake Bay, which provide habitat for much of its flora and fauna. The capital of the Commonwealth is Richmond; Virginia Beach is the most populous city, and Fairfax County is the most populous political subdivision. The Commonwealth's estimated population as of 2018 is over 8.5 million.

Maryland is a state in the Mid-Atlantic region of the United States, bordering Virginia, West Virginia, and the District of Columbia to its south and west; Pennsylvania to its north; and Delaware to its east. The state's largest city is Baltimore, and its capital is Annapolis. Among its occasional nicknames are Old Line State, the Free State, and the Chesapeake Bay State. It is named after the English queen Henrietta Maria, known in England as Queen Mary.

The plaintiff then filed an action in the U.S. District Court for the District of Columbia, which denied jurisdiction based on Rooker's prohibition against federal courts hearing appeals of state court judgments.^[3] The U.S. Court of Appeals for the District of Columbia reversed, saying that this was not the kind of judicial determination that a federal court would be barred from hearing on appeal from a decision of a state court.^[4]

Issue

The Supreme Court considered in this case whether the district court had jurisdiction to review this decision, which required an inquiry into whether the decision to be reviewed is a "judicial" decision, or one that is merely administrative.

Result

The Supreme Court, in an opinion by Justice Brennan, held that the District Court had properly dismissed the case for lack of jurisdiction to hear an appeal of the highest court in a state. The denial of a waiver for admission to the bar, an evaluation of specific facts in light of an existing rule of law, was a judicial determination, only appealable to the Supreme Court.

Jurisdiction is the practical authority granted to a legal body to administer justice within a defined field of responsibility, e.g., Michigan tax law. In federations like the United States, areas of jurisdiction apply to local, state, and federal levels; e.g. the court has jurisdiction to apply federal law.

The Court noted, however, that a facial challenge to the constitutionality of the law would not be considered a review of anything that had been decided by the D.C. Court of Appeals, and remanded this question to the lower court.

Dissent

Justice Stevens dissented, noting that each plaintiff had asked the Court of Appeals to exercise administrative discretion by waiving the requirements, but neither plaintiff had actually sought review of the rule of law itself. Although Feldman had suggested that the rule was in violation of the law, he had not asked for the Court of Appeals to rule that it was, but had merely indicated a challenge that he might bring in the federal district court.

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References

↑ Rooker v. Fidelity Trust Co. , 263 U.S. 413 (1923).
↑ District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 476 (1983).
↑ Hickey v. Dist. of Columbia Court of Appeals, 457F. Supp.584 ( D.D.C. 1978).
↑ Feldman v. Gardner, 661F.2d1295 ( D.C. Cir. 1981).

External links

Text of District of Columbia Court of Appeals v. Feldman, 460 U.S. 462(1983) is available from: Justia Library of Congress Oyez (oral argument audio)

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[1] Rooker v. Fidelity Trust Co. , 263 U.S. 413 (1923).

[2] District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 476 (1983).

[3] Hickey v. Dist. of Columbia Court of Appeals, 457F. Supp.584 ( D.D.C. 1978).

[4] Feldman v. Gardner, 661F.2d1295 ( D.C. Cir. 1981).