The Supreme Court ruled Thursday that federal district courts cannot review state-court judgments that are not yet final, closing a door that civil-rights plaintiffs have used for decades to escape state proceedings they view as hostile. The 5-4 decision in Cabassa v. Gattoni-Celli drew a sharp dissent from Justice Sonia Sotomayor, who warned the majority had stripped a critical federal remedy from litigants caught in prolonged state litigation.
Justice Amy Coney Barrett wrote for the majority, holding that the Rooker-Feldman doctrine bars federal district courts from sitting in review of state-court judgments, and that this prohibition applies equally to non-final state-court orders. The ruling resolved a circuit split that had divided federal appeals courts for years on whether Rooker-Feldman's reach extended beyond final state judgments.
The dispute began as a state-court lawsuit in New Jersey. Alfred Gattoni-Celli sued Jorge Cabassa and others in state court. During those proceedings, Gattoni-Celli obtained certain interlocutory orders from the state trial court. Cabassa then turned to federal court, filing a civil-rights lawsuit under 42 U.S.C. § 1983, the federal statute that allows individuals to sue state actors for constitutional violations. Cabassa's federal suit effectively asked a federal district judge to review and overturn the state trial court's non-final rulings.
The question that reached the Supreme Court was narrow but consequential: Does the Rooker-Feldman doctrine, which prevents federal district courts from functioning as appellate courts over state tribunals, apply only to final state-court judgments, or does it also block review of interlocutory (non-final) orders?
The Third Circuit had ruled that Rooker-Feldman barred Cabassa's federal suit. Other circuits had gone the opposite direction, holding that only final state judgments triggered the doctrine. The Supreme Court took the case to settle the disagreement, as SCOTUSblog reported.
Barrett, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, and Brett Kavanaugh, grounded the holding in the text and history of the two statutes that created the Rooker-Feldman doctrine: 28 U.S.C. § 1257 and 28 U.S.C. § 1331.
Section 1257 gives only the Supreme Court jurisdiction to review state-court judgments. The majority reasoned that if federal district courts could review non-final state-court orders, they would be exercising the very appellate authority that Congress reserved exclusively for the Supreme Court. Barrett wrote that the word "judgments" in Section 1257 encompasses non-final judicial orders, not merely final dispositions.
The opinion traced the doctrine's origins to two cases: Rooker v. Fidelity Trust Co. (1923) and District of Columbia Court of Appeals v. Feldman (1983). Barrett emphasized that neither case limited its logic to final judgments. The principle, she wrote, is structural: federal district courts sit as courts of original jurisdiction, not as appellate courts reviewing state judicial decisions at any stage.
The majority also rejected the argument that barring federal review of non-final state orders would leave litigants without a federal forum. Barrett pointed to two alternative paths. First, a litigant can wait for the state case to conclude and then seek Supreme Court review under Section 1257. Second, a litigant may raise federal defenses within the state proceedings themselves, which state courts are obligated to adjudicate faithfully under the Supremacy Clause.
The 5-4 split placed the Court's conservative justices in the majority and its three liberal members plus Justice Neil Gorsuch in dissent. Gorsuch's alignment with the liberal bloc drew attention, though his reasoning diverged from Sotomayor's in key respects. The configuration underscored a term marked by ideological fractures on questions of federal power and individual rights. The Court has delivered several closely divided rulings this term on politically charged issues.
Gorsuch wrote separately to argue that the majority's reading of "judgments" was too broad and that the original public meaning of the term in the relevant statutes referred to final dispositions. He agreed with the liberal justices that the Rooker-Feldman doctrine should not extend to non-final orders, but he did not join all portions of Sotomayor's dissent.
Sotomayor, joined by Justices Elena Kagan and Ketanji Brown Jackson, wrote the principal dissent. She argued the majority's rule would trap civil-rights plaintiffs in state proceedings for years, with no ability to seek federal relief until the state case ends.
She pointed to scenarios where state-court litigation drags on for a decade or more. Under the majority's framework, a plaintiff alleging that a state judge violated her constitutional rights through an interlocutory order would have no federal forum until every state appeal concluded. Sotomayor called this result "a denial of justice delayed into a denial of justice outright."
The dissent also challenged Barrett's reading of the statutory text. Sotomayor argued that Section 1257's reference to "judgments" historically meant final judgments, and that Congress never intended to strip federal district courts of jurisdiction over Section 1983 claims simply because those claims arose from non-final state-court proceedings. She noted that the Court's 2005 decision in Exxon Mobil Corp. v. Saudi Basic Industries Corp. had already narrowed Rooker-Feldman significantly, and she accused the majority of expanding the doctrine beyond its proper boundaries.
The ruling arrives during a term in which the Court has confronted major constitutional questions across several areas of law, from criminal procedure to individual rights.
The practical impact falls hardest on civil-rights litigants and prisoners who file federal suits challenging ongoing state proceedings. Before this decision, several circuits allowed such plaintiffs to bring Section 1983 claims in federal court even while state litigation continued, so long as they were not asking the federal court to directly reverse a final state judgment. That door is now closed nationwide.
Defense attorneys and state officials are likely to invoke the ruling to dismiss pending federal suits that challenge non-final state orders. The decision also narrows the options for criminal defendants who believe state trial courts are violating their constitutional rights in real time. Those defendants must now raise federal claims within the state system and wait for the process to conclude before seeking federal review.
Civil-liberties organizations had filed amicus briefs urging the Court to preserve federal jurisdiction over non-final state orders. They argued that the alternative routes Barrett identified are inadequate in practice. Supreme Court review under Section 1257 is discretionary, and the Court accepts fewer than 80 cases per term. Raising federal defenses in state court, they contended, provides cold comfort when the alleged constitutional violation is being committed by the state court itself.
The decision stands in contrast to other recent rulings where the Court reached unanimous or near-unanimous consensus. The justices ruled 9-0 in a Second Amendment case earlier this term, showing that agreement is still possible even on politically sensitive subjects. The fracture in Cabassa reflects a deeper disagreement about how much access litigants should have to federal courts when state proceedings are still underway.
For conservatives, the ruling reinforces a core principle: federal courts should not micromanage state judicial proceedings. The majority opinion treats state courts as competent, independent tribunals capable of protecting federal rights within their own systems. That framing aligns with a longstanding conservative legal argument that federal courts have overreached by second-guessing state judges at every turn.
Critics on the left see it differently. They argue the decision guts a practical remedy for people whose rights are being violated in real time by state courts. The tension between these views has animated federal-courts jurisprudence for decades, and Cabassa lands squarely on the side of restraint.
The ruling also carries implications for how lower federal courts handle abstention and jurisdiction questions more broadly. Judges who previously allowed Section 1983 suits to proceed alongside state litigation will now need to dismiss those cases at the threshold. The decision may also influence how federal courts approach related doctrines, including Younger abstention, which independently limits federal interference with ongoing state proceedings.
Internal divisions on the Court have surfaced repeatedly this term. Justice Alito, who joined the majority here, recently issued a pointed separate writing criticizing his colleagues in another case, reflecting the intensity of disagreements behind the bench.
The case now returns to the lower courts for proceedings consistent with the Supreme Court's opinion. Cabassa's federal suit will almost certainly be dismissed. Across the country, litigants with similar pending cases will face motions to dismiss under the newly clarified rule.
Congress could, in theory, override the decision by amending the jurisdictional statutes to explicitly permit federal district court review of non-final state orders. No such legislation is currently pending, and the political appetite for expanding federal court jurisdiction over state proceedings is slim in the current Congress.
For now, the message from the majority is clear: if you want a federal court to review what a state judge did, wait until the state case is over, or take it up with the only federal court that has always had that power, the Supreme Court itself.
Five justices decided that the federal courthouse door stays shut while state cases remain open. Whether that protects federalism or punishes the people who need federal courts most will depend on which side of a state-court order you find yourself on.
