District of Columbia Court of Appeals v. Feldman
The Supreme Court ruled that a federal district court cannot review a District of Columbia court's specific decision denying a particular person's request for a bar-admission waiver, because that kind of review belongs only to the Supreme Court itself.
At the same time, the Court said the district court could still hear a broader claim that the underlying bar rule itself is unconstitutional, since that is a general legal challenge rather than an appeal of one person's case. The ruling drew a line, later called the Rooker-Feldman doctrine, that has shaped when people can sue in federal court after losing in a state or D.C. court.
“United States district courts, therefore, have subject-matter jurisdiction over general challenges to state bar rules, promulgated by state courts in nonjudicial proceedings, which do not require review of a final state-court judgment in a particular case.”
The majority's key line distinguishing general rule challenges from appeals of individual decisions.
How it got here: Federal district courts dismissed both suits for lack of jurisdiction; the D.C. Circuit reversed, and the D.C. Court of Appeals sought and received Supreme Court review.
The Case in Depth
What happened
Marc Feldman and Hickey both wanted to practice law in Washington, D.C., but neither had graduated from an ABA-approved law school, as a D.C. bar rule required. Feldman trained through Virginia's apprenticeship-style path and was already a member of two other state bars; Hickey attended an unaccredited D.C. law school after a Navy career. Both asked the D.C. Court of Appeals to waive the rule for them, but the court refused, so they sued in federal court claiming the rule and its application to them were unconstitutional.
The question before the Court
When two rejected bar applicants sued in federal district court over D.C.'s law-school graduation rule, could that court review the D.C. Court of Appeals' individual denials of their waiver requests?
The Court's answer
Partly — the Court ruled that federal district courts cannot review the D.C. Court of Appeals' specific decisions denying Feldman's and Hickey's individual requests for a law-school waiver, because those denials were judicial acts of the jurisdiction's highest court, reviewable only by the Supreme Court itself. Treating those individual-denial claims as separate lawsuits would effectively let a lower federal court sit in appeal over a decision only the Supreme Court can review.
However, the Court also held that the district court could still hear the applicants' broader claim that the graduation-from-an-approved-law-school rule itself is unconstitutional, since a general attack on a rule's validity doesn't require re-deciding anyone's individual case. So the applicants lost their bid to get their specific denials second-guessed in district court, but kept their ability to challenge the rule itself there.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
The decision limits where people who feel wronged by a state or D.C. court's individual ruling can turn for help: they cannot simply refile in a federal trial court hoping for a different outcome, even if they claim their constitutional rights were violated. This distinction between attacking a rule generally and attacking how it was applied to one person has since guided countless lawsuits trying to challenge state-court decisions in federal court.
What changes now
The case returns to the district court, which may proceed only on the applicants' general constitutional challenges to the bar rule, not on their claims that the D.C. court wrongly denied their individual waiver requests. The Court left open whether prior-litigation rules (res judicata) might still bar even those surviving claims, leaving that question for the district court to resolve on remand.
What this does not decide
The Court did not decide whether the bar rule requiring graduation from an ABA-approved law school is actually unconstitutional — only that a federal district court has power to consider that general question. It also left open whether res judicata (the rule against relitigating already-decided matters) bars the surviving claims.
Concurrences and dissents
Dissent — Justice Stevens
“But it does violence to jurisdictional concepts for this Court to hold, as it does, that the federal district court has no jurisdiction to conduct independent review of a specific claim that a licensing body's action did not comply with federal constitutional standards.”Stevens's core objection that the majority wrongly barred federal review of unconstitutional application claims.
Justice Stevens argued the majority drew a false distinction: neither applicant asked the D.C. court to declare a legal right, so the waiver denials were administrative licensing decisions, not judicial adjudications, and should not have been treated as unreviewable in district court. He also argued that even if the denials were adjudications, federal-question jurisdiction lets a district court hear a genuine constitutional challenge to how a rule was applied, since that is a collateral attack, not an appeal. He would have let both of the applicants' claims proceed.
How the Court got there
The legal reasoning, step by step
- The Court first asked whether the D.C. Court of Appeals' waiver denials were 'judicial' decisions rather than mere administrative or rulemaking acts, since only judicial decisions of a jurisdiction's highest court can be reviewed exclusively by the Supreme Court under the federal statute governing review of state high-court judgments.
- Drawing on earlier cases distinguishing judicial action (applying existing law to specific facts to resolve a claimed right) from legislative or administrative action (setting general rules for the future), the Court found that both applicants had asked the D.C. court to weigh their individual qualifications against the existing rule and rule on whether they were entitled to admission or examination access — a judicial inquiry, not rulemaking.
- Because the waiver denials were judicial acts of the jurisdiction's highest court, the Court held that federal district courts have no authority to review them; such review, win or lose, could be sought only in the Supreme Court itself.
- The Court then distinguished between two kinds of claims a rejected applicant can bring in federal court: a claim that the D.C. court wrongly denied a particular application (which is really an attempt to get a second opinion on the same case) and a claim that the bar rule itself is unconstitutional on its face (a general legal challenge that does not require re-deciding anyone's specific application).
- Applying that distinction, the Court found the applicants' claims that the court acted arbitrarily or inconsistently in denying their own waivers were 'inextricably intertwined' with the court's judicial decisions and therefore outside the district court's power to review.
- But the applicants' broader claims — that the graduation requirement creates an unfair blanket assumption about who is fit to practice law and improperly hands rulemaking power to the American Bar Association — attacked the rule itself rather than its application to them, so the district court retained jurisdiction over those claims.
Doctrinal impact
Cases affected by this decision
Reaffirms Rooker v. Fidelity Trust Co. (263 U.S. 413)
Relies on this earlier case to hold that only the Supreme Court, not lower federal courts, can review state high-court judgments.
Reaffirms In re Summers (325 U.S. 561)
Uses this case's test for judicial versus administrative proceedings to classify the bar waiver denials as judicial.
Reaffirms Prentis v. Atlantic Coast Line Co. (211 U.S. 210)
Applies this case's definition of judicial versus legislative action to find the waiver denials were judicial.