Kevin Cooper v. Michael Ramos

Kevin Cooper was convicted of four counts of first-degree murder and sentenced to death in 1985. Since then his case has traveled up, down and around the federal and state judiciaries. Most recently, Cooper filed suit in federal district court in California challenging a state court’s denial of his request to obtain additional DNA testing pursuant to a state statute. In the complaint, Cooper alleges that he is the target of a long-running conspiracy, involving members of the San Bernardino County Sheriffs Department and others, to manipulate evidence and prevent him from proving that he was framed. The district court dismissed without prejudice on the basis that it lacked subject matter jurisdiction under the Rooker-Feldman doctrine because Cooper’s federal suit constituted a de facto appeal of the state court judgment. We agree that his complaint was properly dismissed. Under the Rooker-Feldman doctrine, the federal courts lack subject matter jurisdiction over his first claim, which sought federal relief from the state court’s determination in the DNA proceeding, and over his second and third claims, which are inextricably intertwined with the first. We further hold that…