T. M. v. University of Md. Medical System Corporation · ¶94

Occasionally, we have also cited 28 U. S. C. §1331 as support for the Rooker-Feldman doctrine, observing that it gives district courts “original,” not appellate, jurisdiction. Rooker, 263 U. S., at 416. This observation adds nothing— as just explained, a collateral attack is not the functional equivalent of an appeal. Besides, §1331 cannot explain why Rooker-Feldman has always been limited to collateral attacks on state-court judgments. If entertaining a collateral attack goes beyond “original jurisdiction,” then it should not matter whether the underlying judgment is from a state court or a federal one. Yet it is well settled that district courts can entertain collateral attacks on federal judgments—for example, an independent action for relief from a judgment to prevent a “grave miscarriage of justice.” United States v. Beggerly, 524 U. S. 38, 45–47 (1998); see Fed. Rule Civ. Proc.…

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