In re: Philadelphia Entertainment & Development Partners — bankruptcy / civil — reversal — Greenberg

For all of you who’ve been dying for a Third Circuit Rooker-Feldman opinion–you know who you are–today’s your day. The Rooker-Feldman doctrine, today’s opinion explains, “deprives federal district and bankruptcy courts of jurisdiction over suits that are essentially appeals from state-court judgments.” (Cleaned up). Today’s opinion is about how Rooker-Feldman applies when a bankruptcy trustee alleges that a state-court ruling amounted to a voidable fraudulent transfer. The district court had ruled Rooker-Feldman barred review of the fraudulent-transfer claims, but today the Third Circuit reversed because review of the claims did not require review of the state-court judgment. The court rejected as unpersuasive a Seventh Circuit opinion relied on by the bankruptcy court.

By the way, the court posted this opinion on its website in the morning, instead of posting it around 12:34 p.m. as it always has. Fluke? Mistake? New practice? I’m curious.

Joining Greenberg were Chagares and Restrepo. The case was (surprisingly) decided without oral argument.