Rooker-Feldman Bars Federal Attacks on State Fee Judgments but Not Independent Tort Claims Based on Underlying Conduct

I. Introduction

In William Covert v. Arielle Hacking (11th Cir. Sept. 4, 2026) (per curiam) (unpublished), the Eleventh Circuit applied the modern, “narrow” understanding of the Rooker-Feldman doctrine to a pro se litigant’s effort to reframe dissatisfaction with Utah state-court outcomes as a federal civil-rights case.

Parties. Plaintiff-Appellant William Covert sued (1) Arielle C. Hacking (the opposing party in his Utah defamation case), (2) Utah Attorney General Derek Brown, and (3) several Utah state judges.

Background. Covert lost (or otherwise fared adversely) in Utah state court litigation stemming from a defamation dispute and was assessed attorney’s fees. In federal court (Middle District of Florida), he filed an amended complaint styled under 42 U.S.C. § 1983 with three counts:

  • Count One: an “as-applied” constitutional challenge to Utah’s attorney-fee statute as used in his case, seeking injunctions undoing adverse state decisions and preventing enforcement of the fee statute against him.
  • Count Two: a constitutional claim (free speech, due process, equal protection) alleging improper exclusion of an affidavit in state proceedings, seeking the same injunctive relief.
  • Count Three: state-law tort claims (defamation, injurious falsehood, and intentional infliction of emotional distress) against Hacking, alleging ongoing harm from continued dissemination of false information and management of the Facebook page implicated in the Utah dispute.

The district court dismissed all counts for lack of subject-matter jurisdiction under Rooker-Feldman (during 28 U.S.C. § 1915(e) screening after Covert sought to proceed in forma pauperis). The Eleventh Circuit affirmed as to Counts One and Two, but vacated and remanded as to Count Three.

II. Summary of the Opinion

The Eleventh Circuit held that Rooker-Feldman barred Counts One and Two because, in substance, Covert sought federal relief that would require review and rejection of the Utah state-court fee judgment (and related adverse rulings). But Rooker-Feldman did not bar Count Three because the alleged injuries there flowed from Hacking’s purportedly wrongful conduct (the allegedly defamatory activity), not from the state-court judgment itself—even if Count Three might be an attempt to relitigate issues already resolved in state court.

The court emphasized that other doctrines—particularly preclusion—may still defeat Count Three, leaving those questions for the district court on remand.

III. Analysis

A. Precedents Cited

1. Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983)

These foundational cases establish that federal district courts are not appellate tribunals over state courts. The district court relied on this lineage to dismiss; the Eleventh Circuit accepted the doctrine’s core premise but applied its modern limitation (as articulated in later Supreme Court and Eleventh Circuit precedent).

2. Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005)

Exxon Mobil is the controlling modern limiter: Rooker-Feldman occupies “narrow ground” and applies only when the plaintiff is a state-court loser complaining of injuries caused by the state-court judgment and seeking federal review and rejection of that judgment. The Eleventh Circuit invoked Exxon Mobil twice:

  • to characterize Counts One and Two as falling within that narrow zone because the requested injunction would effectively negate the Utah fee judgment; and
  • to explain why Count Three could still be within federal jurisdiction as an “independent claim,” leaving preclusion to state law.

3. Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021)

Behr supplies the Eleventh Circuit’s operative framework: courts must look past labels and focus on substance; Rooker-Feldman “bars all appeals of state court judgments” even if packaged as something else, but it does not eliminate jurisdiction merely because a matter was previously litigated in state court. The court used Behr to:

  • support rejecting Covert’s characterization of Counts One and Two as merely “prospective” constitutional relief; and
  • distinguish Count Three as potentially duplicative but not jurisdictionally barred.

4. T.M. v. Univ. of Md. Med. Sys. Corp., 146 S. Ct. 1739 (2026)

The court quoted T.M. for the now-standard formulation of Rooker-Feldman (itself quoting Exxon Mobil): federal district courts lack jurisdiction over suits by state-court losers complaining of injuries caused by state-court judgments rendered before federal proceedings commenced and inviting federal review and rejection of those judgments. The citation shows the Eleventh Circuit aligning its analysis with the Supreme Court’s most recent restatement.

B. Legal Reasoning

1. The court’s “injury source” inquiry

The decisive move is the court’s identification of the source of the alleged injury:

  • Counts One and Two: the injury was the existence and enforcement of the Utah state-court decisions—most concretely, the attorney-fee award against Covert. Although framed as constitutional challenges (including an “as applied” attack on a fee statute and an alleged wrongful evidentiary exclusion), the remedy sought was injunctive relief undoing or preventing enforcement of the adverse state outcomes. To grant that relief, a federal court would have to review and reject the state judgment, triggering Rooker-Feldman.
  • Count Three: the injury was ongoing harm allegedly caused by Hacking’s conduct (spreading false information and running the relevant Facebook page). That injury does not arise from the state-court judgment itself, even if the same events were litigated in Utah. Under Behr and Exxon Mobil, relitigation concerns implicate preclusion—not jurisdiction.

2. “Prospective relief” cannot camouflage an impermissible appeal

Covert argued he sought prospective declaratory/injunctive relief for constitutional violations. The court rejected this as a matter of substance over form: where the practical effect of the requested relief is to nullify a state-court judgment (here, the fee award and associated rulings), the claim is a forbidden de facto appeal.

3. The opinion’s deliberate restraint on alternative grounds

The Eleventh Circuit explicitly flagged that “[o]ther preclusion and abstention doctrines remain alive and well” and declined to decide those issues. This reflects a key feature of post-Exxon Mobil Rooker-Feldman jurisprudence: courts should not expand a jurisdictional bar to do work properly done by merits or quasi-merits doctrines (claim/issue preclusion, abstention, immunity, pleading standards).

C. Impact

1. For Rooker-Feldman litigation in the Eleventh Circuit

Although unpublished, the decision reinforces a practical rule that will shape screening-stage and motion-to-dismiss disputes:

  • Barred: federal claims that would functionally enjoin, unwind, or declare invalid a state-court judgment (including a fee award), even when cast as constitutional challenges to statutes or procedures used in the state case.
  • Not barred: claims alleging injuries from an opposing party’s underlying conduct (e.g., defamation-type harms) rather than the state judgment— with the understanding that preclusion or other defenses may still apply.

2. For fee-award challenges framed as § 1983 claims

The court’s treatment of Counts One and Two signals that litigants cannot use § 1983 to obtain federal injunctive relief that would effectively erase a completed state-court fee award. Such challenges must proceed through state appellate channels and, where appropriate, Supreme Court review—not through a federal district court.

3. For cases blending federal constitutional claims and state tort claims

The remand posture highlights a recurring procedural reality: even when Rooker-Feldman does not apply to a state-law tort count, plaintiffs may still face substantial barriers on remand—especially preclusion (claim and issue preclusion) based on the prior state judgment, and potentially other jurisdictional or procedural hurdles not addressed in this opinion.

IV. Complex Concepts Simplified

  • Rooker-Feldman doctrine: a jurisdiction rule. Federal district courts cannot act as appellate courts reviewing state-court judgments. If the harm you complain about is the state-court judgment itself, and your requested relief would require a federal court to reject it, the federal court lacks power to hear the case.
  • “Injury caused by the judgment” vs. “injury caused by conduct”: If your injury exists because the state court ruled against you (e.g., you must pay fees), that points to Rooker-Feldman. If your injury stems from someone’s actions outside the judgment (e.g., allegedly defamatory speech), Rooker-Feldman usually does not apply.
  • Preclusion (res judicata/collateral estoppel): not about power, but about whether you already had your chance. Even if a federal court has jurisdiction, it may dismiss because a state court already resolved the same claim or issues.
  • 28 U.S.C. § 1915(e) screening: when a litigant proceeds without paying filing fees, courts must screen and may dismiss certain deficient cases early, including where jurisdiction is lacking.

V. Conclusion

The Eleventh Circuit’s decision draws a clean line consistent with Exxon Mobil Corp. v. Saudi Basic Indus. Corp. and Behr v. Campbell: federal courts lack jurisdiction over claims that, in substance, seek to overturn state-court judgments (Counts One and Two), but retain jurisdiction over claims alleging harm from an opposing party’s underlying conduct (Count Three), even if those claims may ultimately be defeated by preclusion or other doctrines. The case thus reinforces Rooker-Feldman’s narrow scope while preserving traditional, non-jurisdictional tools for handling attempted relitigation on remand.