Thompson v. Reeve
Federal courts can abstain from considering a complaint, pursuant to the Rooker-Feldman doctrine, if: 1.) the plaintiff lost in state court; 2.) the plaintiff alleges injuries from the state court judgment; 3.) the plaintiff requests District Court review of the state court judgment; and 4.) the state court judgment was entered prior to the commencement of the federal court suit. In 2007, the plaintiff, Mel Thompson, was sued in Connecticut Superior Court for breach of contract. Thompson filed a counterclaim, also alleging breach of contract. The Superior Court bifurcated the trial, and Thompson was not permitted to present evidence about his counterclaim in the case in chief. Thompson claimed that evidence about his counterclaim was crucial to his defense to breach-of-contract claims and that as a pro se litigant he lacked access to the state's electronic filing system. Thompson filed an appeal from a court order on a prejudgment remedy, and the appeal was dismissed, allegedly because it did not include a court reporters' acknowledgment form. Thompson sued Chase Rogers, chief justice of the Connecticut Supreme Court, and William Lavery, chief court administrator, as well as other court administrators, alleging that court decisions, the Connecticut Practice Book and the Connecticut General Statutes were unconstitutional. The District Court found it lacked jurisdiction under the Rooker-Feldman doctrine with respect to the state court's decisions to dismiss the plaintiff's appeals. The 11th Amendment shielded the defendants from the plaintiff's remaining claims, alleging that his rights were violated during the administration of his state court case. The plaintiff requested retrospective relief, against the defendants in their official capacities, and did not allege a continuing violation of the law. The District Court lacked subject-matter jurisdiction, pursuant to the Rooker-Feldman doctrine and the 11th Amendment, and it granted the defendants' motion to dismiss.