Long way from Merced NWR (Western Michigan last summer) but I am happy to take this completely gratuitous opportunity to share one of my favorite sandhill crane shots 😍
Jeff Nye
@jeffreynye.org
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Cincinnati lawyer (civil, commercial, real estate litigation, speech defense, and appeals). Likes to take photos of birds. Local elected official, but this is a personal account.
![Donathan argue that Klosterman’s claims are barred by the Rooker-Feldman doctrine. (Doc. 53
at PageID 516–517; Doc. 54 at PageID 529–531; Doc. 55-1 at PageID 783–785.) The Rooker-
Feldman doctrine precludes lower federal courts “from exercising appellate jurisdiction over
final state-court judgments.” Lance v. Dennis, 546 U.S. 459, 463 (2006). The doctrine also
prohibits district courts from exercising jurisdiction over interlocutory state court judgments, see
RLR Invs., LLC v. City of Pigeon Forge, Tenn., 4 F.4th 380, 396 (6th Cir. 2021), and claims that
are “inextricably intertwined with issues decided in state court opinions[,]” Exec. Arts Studio,
Inc. v. City of Grand Rapids, 391 F.3d 783, 793 (6th Cir. 2004) (internal quotation and citation
omitted). “A federal claim is inextricably intertwined with a state court judgment and thus
implicates Rooker-Feldman when the federal claim succeeds only to the extent that the state
court wrongly decided the issues before it.” Exec. Arts Studio, Inc., 391 F.3d at 793 (internal
quotation and citation omitted). Put differently, Rooker-Feldman applies if “the source of the
plaintiff’s injury is the state-court judgment itself.” Kost v. Hoseth Kreeger, 832 F. App’x 438,
439 (6th Cir. 2021).
Defendants argue that Rooker-Feldman precludes this Court from exercising jurisdiction
over the Amended Complaint because the gravamen of Klosterman’s claims is that Defendants
conspired to use a court-appointed receivership to wrongfully deprive him of properties worth
more than $4.5 million. Klosterman does not meaningfully respond to their arguments—he only
asserts in conclusory fashion that Rooker-Feldman does not apply when Defendants commit
crimes in state court proceedings. (Doc. 59 at PageID 1360.)7 As explained immediately below,
7 Although Klosterman has not clearly asserted the issue nor provided legal analysis on it, the Court notes that the
extrinsic fraud exception to Rooker-Feldman does not apply. There is an exception to the…](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:zqssluogi76dnrwjq6aygi44/bafkreidzwidgsj47omak5pdq4uxe3lgp73uubnicsbxeofeuf2vkt7scbi)
