Gordon Rees Scully Mansukhani, LLP
MONTH-IN-BRIEF (Sep 2026)
The following pieces are part of a series of summaries of the leading cases related to bankruptcy decided in the last year and a half.
Barton/Rooker-Feldman Doctrine: Akhlaghpour v. Orantes (In re Akhlaghpour), 164 F.4th 1139 (9th Cir. 2026)
By Le Tong, Columbia Law School
Under the Barton doctrine, a person who sues a lawyer appointed by the bankruptcy court for acts done in the lawyer’s official capacity in a forum other than the bankruptcy court must seek leave of the bankruptcy court to do so. In re Akhlaghpour, 164 F.4th 1139, 1142 (9th Cir. 2026) (citing Barton v. Barbour, 104 U.S. 126 (1881)).
Under the Rooker-Feldman doctrine, federal district courts generally lack jurisdiction over “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005).