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Civil Procedure — Rooker-Feldman doctrine

United States Court of Appeals For the Seventh Circuit


Civil Procedure — Rooker-Feldman doctrine

The Rooker-Feldman doctrine bars an applicant for admission to a state bar from suing the state admission board in federal district court.

“Like the applicant in Hale, Brown had an opportunity to raise federal constitutional claims before a state court with power to adjudicate them. Thus, Indiana Admissions and Discipline Rule 14 § 2 provides that an applicant aggrieved by the final action of the BLE may ‘file a petition with the Supreme Court of Indiana requesting review by [the] Court of such final determination, and setting forth specifically therein the reasons, in fact or law, assigned as error in the [BLE’s] determination . . . . [T]he Court shall enter such order as in its judgment is proper, which shall thereupon become final.’ Rule 14 § 2. Brown did claim before the Indiana Supreme Court that he had suffered unconstitutional discrimination. As its order indicates, that court ‘carefully reviewed’ these contentions and ultimately determined that they did not merit reversal of the BLE’s admission determination. Because Brown is attempting to raise similar violations here, his claims are barred.”


11-2164 Brown v. Bowman

Appeal from the United States District Court for the Northern District of Indiana, Springmann, J., Cudahy, J.

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