Third Circuit Blocks ‘Do-Over’ Under Rooker-Feldman Doctrine

A recent Third Circuit decision supports the general proposition that a bankruptcy proceeding cannot be used to revive foreclosure-related disputes that have been previously and conclusively resolved by a state court.

6 minute read December 01, 2025 at 12:07 AM

Francis J. Lawall and Amita Chohan

Third Circuit Blocks ‘Do-Over’ Under Rooker-Feldman Doctrine

It is not unusual for a debtor to try to escape a negative state court ruling by filing bankruptcy and seeking a “do over.” In a recent U.S. Court of Appeals for the Third Circuit decision, In re Eileen T. Adams, Case No. 24-1212, 3rd Cir.

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