In the case of Rooker et al. v. Fidelity Trust Company et al., 1923, the U.S Supreme Court established what is now known as the "Rooker-Feldman doctrine". The plaintiffs, who had lost in Indiana state court regarding a foreclosure on their property, sought to have their case reviewed by federal courts due to alleged constitutional violations by the state judiciary. However, they were denied this opportunity because it was determined that only the Supreme Court has jurisdiction over appeals from final judgments of a state court. This ruling essentially means that lower federal courts do not have authority to review decisions made by state courts; such power resides solely with the U.S Supreme Court under certain circumstances outlined in Section 1257 of Title 28 of United States Code.

In the dissenting opinion for Rooker et al. v. Fidelity Trust Company et al., Justice McReynolds disagreed with the majority's ruling that federal courts lack jurisdiction to review state court decisions, arguing it undermined citizens' constitutional rights and protections. He contended that this interpretation of the Judiciary Act of 1789 was incorrect and overly restrictive, effectively denying individuals their right to seek redress in federal courts when they believe their constitutional rights have been violated by a state court decision. Furthermore, he argued that such an interpretation could potentially allow states to infringe upon individual liberties without any checks or balances from federal authorities. Thus, he believed that the Supreme Court should be able to exercise appellate jurisdiction over final judgments and decrees rendered by state courts in civil actions where there is a claim under U.S Constitution or Federal law.