Cooks v. City of Los Angeles Police Department

Background

Charles R. Cooks, a state prisoner incarcerated at California State Prison, Solano, filed this action without a lawyer. He sought to appeal or vacate the dismissals of two civil-rights actions he had filed in California state superior courts. The Amador County Superior Court dismissed one action on December 7, 2018; that case involved various Los Angeles Police Department employees. The Merced County Superior Court dismissed the other action on March 3, 2018; that case involved various Los Angeles County Superior Court employees.

Reason for dismissal

The court held that federal district courts lack subject-matter jurisdiction—the power to hear a case—to review state-court decisions. It applied the rule commonly called the Rooker-Feldman doctrine, which prevents a federal district court from acting as an appeals court over a state-court judgment. The court explained that this rule applied even though the state-court decisions were not made by the highest state court and even though federal constitutional issues were involved.

Other rulings and disposition

The court dismissed Cooks’s action. Based solely on his affidavit of poverty, it granted his motion to proceed without paying filing fees. The clerk was instructed to terminate all other pending motions as moot and close the case. The opinion does not specify whether the dismissal was with or without prejudice.