Restricting Federal Review of State Court Judgments: Rooker‐Feldman and State‐Actor Boundaries in Civil Rights Litigation

Introduction

The appeal in Swenson I v. Vedder (3d Cir. No. 24-2652, 2025) arises from a protracted state guardianship proceeding concerning the late Ella Card. In 2011 three of her adult children petitioned to declare her incapacitated and appointed a professional guardian for her property. Over the next decade, Ella Card and her dissenting children repeatedly sought to remove or challenge that state-court appointment in federal district court but were remanded back to state court each time. After Ella’s death in February 2022, two of her children (Raymond and Kermit) asked the Orphans’ Court to enforce their co-guardianship; the other side (Cindy, LaDonna and Ken) sued in federal court under 42 U.S.C. §§ 1983, 1985, 1986 and 18 U.S.C. §§ 241, 242, alleging constitutional violations, fraud, elder abuse and seeking to void or enjoin state-court orders. The district court dismissed all federal claims on jurisdictional grounds (Rooker-Feldman, Eleventh Amendment, judicial immunity, failure to allege state action or conspiracy) and declined supplemental jurisdiction over state-law claims. The Third Circuit affirmed.

Summary of the Judgment

The district court lacked subject-matter jurisdiction to review or void state court judgments under the Rooker-Feldman doctrine.
Judge Vedder was immune both in his official capacity (Eleventh Amendment) and his personal capacity (judicial immunity) for actions taken in court.
None of the private‐party defendants (counsel or co-guardians) were “state actors” under § 1983, nor did plaintiffs properly allege a conspiratorial agreement to attribute state action.
Claims under §§ 1985 and 1986 failed for lack of any plausible conspiracy allegations; criminal statutes (18 U.S.C. §§ 241, 242) cannot be enforced by private civil suits.
The district court did not abuse its discretion in dismissing with prejudice and declining to exercise supplemental jurisdiction over state-law claims.

Analysis

Precedents Cited

The court grounded its ruling on long‐standing Supreme Court and Third Circuit precedents:

Rooker v. Fid. Tr. Co. (263 U.S. 413) and District of Columbia Court of Appeals v. Feldman (460 U.S. 462): Established the principle that federal district courts lack jurisdiction to review final state‐court judgments or issues “inextricably intertwined” with them.
Exxon Mobil Corp. v. Saudi Basic Industries Corp. (544 U.S. 280): Clarified the scope of the Rooker‐Feldman doctrine—only state‐court losers seeking federal review of adverse state rulings are barred.
Benn v. First Judicial District of Pa. (426 F.3d 233): Confirmed that state judges sued in their official capacity are protected by the Eleventh Amendment.
Stump v. Sparkman (435 U.S. 349): Held that judges enjoy absolute immunity for judicial acts, even if those acts exceed jurisdiction or are done maliciously.
Abbott v. Latshaw (164 F.3d 141) and Angelico v. Lehigh Valley Hosp. (184 F.3d 268): Defined the “state‐actor” requirement under § 1983, and rejected bare conspiracy allegations absent factual detail.
D.R. by L.R. v. Middle Bucks (972 F.2d 1364): Emphasized that Section 1985 conspiracies must be pleaded with sufficient factual support to allow an inference of joint action.

Legal Reasoning

1. Rooker-Feldman Jurisdictional Bar. Plaintiffs sought to overturn or enjoin state court rulings—clear Rooker-Feldman territory. The Third Circuit reaffirmed that federal district courts may not entertain collateral attacks on state judgments rendered before the federal litigation commenced.

2. Judicial Immunity. Judge Vedder’s ex parte order requiring an accounting was a quintessential judicial act. Under Stump v. Sparkman, absolute immunity shields him—even if the order was unfair or erroneous.

3. Eleventh Amendment Immunity. Suing a state‐court judge in his official capacity is effectively a suit against the state. Benn holds such suits barred by the Eleventh Amendment absent waiver or congressional abrogation.

4. State‐Actor Requirement & Conspiracy Pleading. Liability under § 1983 requires the defendant to act “under color of state law.” Private attorneys and co-guardians do not become state actors merely by participating in state proceedings. Nor did plaintiffs allege factual details of a conspiracy between Judge Vedder and the private parties—conclusory assertions cannot substitute for specific allegations of a “meeting of the minds.”

5. Section 1985/1986 Claims. Dependent on a valid conspiracy to deprive civil rights, these claims fail when the § 1983 conspiracy fails. Section 1986 adds no independent cause of action once § 1985 is dismissed.

6. Criminal Statutes in Civil Suits. Private citizens have no cause of action under 18 U.S.C. §§ 241–242. As Linda R.S. v. Richard D. (410 U.S. 614) instructs, there is no private right to enforce federal criminal laws.

Impact

This decision underscores two critical jurisdictional and substantive limits in civil-rights litigation:

Federal courts will not serve as appellate forums for state courtroom decisions. Litigants dissatisfied with state-court guardianship or similar rulings must exhaust state remedies and use state appellate procedures.
Private actors must exhibit significant state involvement before being deemed “state actors.” Participation in a state judicial proceeding—without more—cannot be shoe-horned into § 1983 liability by alleging conspiracy.

Future litigants will face exacting standards when seeking to challenge state court determinations or target private attorneys and non‐state officials under federal civil‐rights statutes.

Complex Concepts Simplified

Rooker-Feldman Doctrine: A rule barring federal district courts from overruling or reviewing final decisions of state courts.
Eleventh Amendment Immunity: States and state‐level officials sued in their official capacities cannot be sued in federal court without consent.
Judicial Immunity: Judges are absolutely protected from civil liability for actions taken in their judicial roles, even if mistaken or malicious.
State Actor: To sue under § 1983, you must show the defendant was performing a public function under state authority, not merely appearing in state court as a private participant.
Conspiracy Pleading: You cannot rely on vague allegations of concerted wrongdoing—you must specify who agreed with whom, when, and how they acted together to deprive you of rights.

Conclusion

Swenson I v. Vedder reaffirms that federal courts are not venues to relitigate or nullify state judicial determinations. It highlights the breadth of judicial and Eleventh Amendment immunity, and the stringent requirements for establishing state action and conspiratorial liability under §§ 1983, 1985, and 1986. Litigants challenging guardianship proceedings—or any state-court adjudication—must heed these jurisdictional ceilings and focus on proper state‐court remedies or tailor § 1983 claims with detailed factual underpinnings of state involvement.