Under the Rooker-Feldman doctrine, a federal district court cannot entertain appeals of state court default judgments confirming arbitration awards, according to a federal district court in Utah.

In Forte v. Chase Manhattan Banks USA, No. 2:07-CV-669 TS, 2007 WL 4210258 (D. Utah Nov. 27, 2007), Forte and Chase agreed by contract to arbitrate disputes between the parties regarding a consumer credit account. Chase submitted a dispute to the National Arbitration Forum, and the arbitrator entered an award in favor of Chase. Chase then confirmed the arbitration award in a Utah state court, obtaining a default judgment against Forte.

Forte then filed a petition to vacate and stay the judgment of the Utah state court with the Federal District Court of Utah. The Court found Forte's petition to be an attack on the state court's judgment, held that it had no subject matter jurisdiction to entertain Forte's motion, and granted Chase's motion to dismiss.

Specifically, the Court observed that the Rooker-Feldman doctrine prevented the exercise of federal court jurisdiction for cases "brought by state-court losers challenging state-court judgments rendered before the district court proceedings commenced," the very type of action brought to the Court by Forte. See Dist. of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462 (1983); Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923).