Rooker-Feldman Doctrine.

In Cho v. City of New York, the plaintiffs had been charged with violating New York City's Nuisance Abatement Law.  They entered into settlement agreements with the City rather than defend themselves in court.  Each of the agreements were "so-ordered" by the state court.  The New York law allowed ex parte orders, requiring a premises on which an alleged public nuisance was being conducted to be closed.

Bringing a federal action against the City, the plaintiffs asserted that the City used the state court actions to compel property owners and leaseholders to enter into settlement agreements waiving their constitutional rights and that the so-ordered so-ordered settlement agreements violated the Fourteenth Amendment.  They asked the district court to enjoin the City from enforcing the agreements and declare them to be unconstitutional, invalid and unenforceable.  The City moved to dismiss and the district court granted the motion, claiming that it had no jurisdiction over the matter under the Rooker-Feldman Doctrine.  The Rooker-Feldman doctrine provides that federal district courts lack jurisdiction over suits that are, in substance, appeals form state court judgments.

For a district court to be without jurisdiction under this doctrine, four requirements must be met.  First, the plaintiff in the federal action must have lost in state court.  Second, the plaintiff must complain of injuries caused by a state court judgment.  Third, the plaintiff must invite district court review and rejection of that judgment.  Fourth, the state court judgment must have been rendered before the district court proceedings had been commenced.

The Second Circuit reversed, holding that where the state court action did not cause the injury but was a mere ratification of it, the second requirement of the Rooker-Feldman doctrine had not been met and the district court was not deprived of jurisdiction.  The injury that the plaintiffs sought to remedy was an injury caused when, prior to any judicial action, they were coerced to settle, not an injury that flows from a state court judgment.  Accordingly, the judgment was vacated and the case remanded to the district for further proceedings.

The decision in this case can be found here.