In the case of Rooker et al. v. Fidelity Trust Company et al., 1922, the U.S Supreme Court established what is now known as the "Rooker-Feldman doctrine". The plaintiffs, who had lost a foreclosure lawsuit in Indiana state court and failed to appeal within that system, sought relief from federal courts on constitutional grounds. They argued that they were deprived of their property without due process of law by virtue of an erroneous judgement rendered by a state court. However, the Supreme Court ruled against them stating that only it has jurisdiction to review final judgments or decrees rendered by highest courts in states where there is no further judicial authority available for correction or amendment under local law (28 USC §1257). This decision effectively barred lower federal courts from reviewing cases already decided at state level unless Congress specifically provides otherwise.

In the dissenting opinion for Rooker et al. v. Fidelity Trust Company et al., Justice Holmes argued that the Supreme Court should not have jurisdiction over this case as it was a matter of state law, and therefore outside its purview. He contended that the majority's decision to hear the case represented an unwarranted expansion of federal power into areas traditionally reserved for states' courts. Furthermore, he disagreed with their interpretation of due process rights under Fourteenth Amendment, arguing instead that these rights were not violated by Indiana’s tax sale laws which led to plaintiffs losing their property without notice or compensation because they failed to pay taxes on time. In his view, such laws did not constitute deprivation but rather served as legitimate means for states to collect unpaid taxes from delinquent taxpayers.