..."); Kougasian v. TMSL, Inc., 359 F.3d 1136, 1141 (9th Cir. 2004) (same). Other circuits, however, have rejected this exception to Rooker-Feldman. E.g., Taylor v. Fed. Nat'l Mortg. Ass'n, 374 F.3d 529, 533 (7th Cir. 2004) (holding Rooker-Feldman barred fraud-on...Rooker-Feldman.").
We have not explicitly rejected a fraud exception to Rooker-Feldman, but an unpublished decision cast considerable doubt on it. See West v. Evergreen Highlands Ass'n, 213 Fed.Appx. 670, 674 n.3 (10th Cir. 2007). As the court explained in West, "[t]here is good reason to balk at" adopting such a fraud exception because...]tate rules of procedure provide various means to attack a wrongfully obtained judgment." Id. "Construing Rooker-Feldman to permit federal reconsideration and nullification of state judgments on grounds that could have been pursued in state court arguably allows under the rubric of collateral attack just another mechanism for lower federal court review unauthorized under § 1257." Id.
In addition, we note that the decision that first adopted the fraud exception, In...