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In dismissing an action seeking vacatur of an arbitration award that was confirmed in state court, a California federal court held that, under the Rooker-Feldman doctrine, it lacked subject matter jurisdiction to hear the dispute.
In Nitzke v. Seivers, No. CIVS061937 FCD KJMPS, 2007 WL 2688434 (E.D. Cal. Sep 10, 2007), Nitzke filed an action in federal court, seeking vacatur of an arbitration award that was confirmed in state court.
The Court dismissed the complaint, holding that it lacked subject matter jurisdiction under the Rooker-Feldman doctrine. The Rooker-Feldman doctrine precludes a federal court from conducting a direct review of state court judgments or scrutinizing the state court’s application of various rules and procedures pertaining to state cases.
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