Mayotte v. U.S. Bank National Association

HARTZ, Circuit Judge., On this appeal the parties have asked us to determine how, or even whether, an important—but subtle and often confusing—doctrine limiting federal-court jurisdiction should apply to a unique Colorado procedure for “nonjudicial” foreclosure of mortgages. The jurisdictional doctrine is the Rooker-Feldman doctrine, which forbids lower federal courts from reviewing state-court civil judgments. Colorado’s unique procedure is Colorado Rule of Civil Procedure 120, which requires creditors pursuing nonjudicial foreclosure to first obtain a ruling by a Colorado trial court that…