T. M. v. University of Md. Medical System Corporation · ¶95

Beyond the difficulties of finding a statutory basis for Rooker-Feldman, parts of the United States Code undercut it. The doctrine is in tension, to say the least, with statutes granting district courts jurisdiction in categorical terms. Section 1331 gives district courts “original jurisdiction” over “all civil actions” presenting a federal question—not “all civil actions” presenting a federal question “minus those that attack a state-court judgment.” The other jurisdictional grants are similar. See, e.g., 28 U. S. C. §1332 (“The district courts shall have original jurisdiction of all civil actions” meeting certain diversity and amount-in-controversy requirements). None has a carveout for collateral attacks.

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