Swartz v. Heartland Equine Rescue

Dist. Ct. lacked jurisdiction under Rooker-Feldman doctrine to consider and then resolve plaintiffs’ action alleging that defendants conspired to deprive them of several goats and horses, where state-court had previously entered orders finding probable cause to seize said animals and then ordering permanent placement of said animals. Rooker-Feldman doctrine, which precludes lower federal courts from exercising jurisdiction over claims seeking review of state court judgments, applied where instant federal action was “inextricably intertwined” with prior state court action, and state court’s finding of probable cause and seizure of said animals produced injury claimed by plaintiffs in instant action. Moreover, plaintiffs had opportunities to litigate instant claims in state court.