Eighth Circuit Affirms District Judge Leon Holmes's Application of the Rooker-Feldman Doctrine
After unsuccessfully challenging a default judgment entered in a suit filed in Pulaski County Circuit Court, and failing to timely file a notice of appeal, the appellant in Skit International, Ltd v. DAC Technologies of Arkansas, No. 06-3493, filed a diversity suit in the Eastern District of Arkansas. District Judge Leon Holmes dismissed the suit via the Rooker-Feldman doctrine, which "prohibits lower federal courts from exercising appellate review of state court judgments." The Eighth Circuit held, in an opinion written by Circuit Judge Diane Murphy, that: "Skit's federal complaint is in many ways a classic illustration of the cases covered by the Rooker-Feldman doctrine."
One of Skit's arguments was that it had been deprived of appellate review of the state-court judgment. The Eighth Circuit gave this argument short shrift: "we decline to exempt from Rooker-Feldman a party whose appeal was not heard because it was considered untimely."
