Bear v. Patton, 451 F.3d 639 (10th Cir. 2006). · Go Syfert
Bear v. Patton, 451 F.3d 639 (10th Cir. 2006). Cases Citing This Book View Copy Cite
115 citation events (115 in the last 25 years) across 17 distinct courts.
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At page 641 Applying the Rooker-Feldman doctrine to state court judgments59 citing cases[O]nly the Supreme Court has jurisdiction to hear appeals from final state court judgments.4 citing courts put it this way · 57 listed here · 1 cautionary
  • In Re Lee, 428 B.R. 667 (Bankr. D.S.C. 2009).published Cited "but see"
    (interpreting Exxon Mobil to limit Rooker-Feldman’s applicability to state court decisions only once the state proceedings are completed, or the state order is otherwise unappealable)
  • Heneck (ID 112732) v. Corby, No. 5:23-cv-03166 (D. Kan. Jan. 14, 2025).
    ([O]nly the Supreme Court has jurisdiction to hear appeals from final state court judgments.)
  • Hinkley, No. 2:26-cv-00035 (D. Utah Feb. 25, 2026). 2 cites
    Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006).
  • Labonte, No. 1:25-cv-02947 (D. Colo. Feb. 10, 2026).
    “The Rooker-Feldman doctrine provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoting Bear v. Patton, 451 F.3d…
  • Rueb v. McCarville, No. 25-1135 (10th Cir. Jan. 27, 2026).unpublished
    “[f]ederal district courts do not have jurisdiction to review state court judgments or claims inextricably intertwined with them”
  • Maestas v. New Mexico Parole Bd., No. 1:24-cv-01134 (D.N.M. Aug. 6, 2025).
    To the extent Maestas seeks to appeal the state mandamus rulings, relief is not available. “[O]nly the [United States] Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880…
  • Rogers v. Brown, No. 24-8075 (10th Cir. Apr. 21, 2025).unpublished
    Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006).
  • Rogne v. City of Catoosa, No. 4:24-cv-00307, 2025 WL 582563 (N.D. Okla. Feb. 21, 2025).
    “review state court judgments or claims inextricably intertwined with them”
  • Williams v. State of Colorado, No. 1:23-cv-01312 (D. Colo. Sept. 9, 2024).
    Rooker-Feldman Doctrine7 “The Rooker-Feldman doctrine is derived from 28 U.S.C. § 1257 (a), and it ‘provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.’” Suasnavas v. Stover, 196 F. App’x…
  • Viegas v. Owens, No. 1:23-cv-02939 (D. Colo. Aug. 23, 2024).
    The Rooker-Feldman Doctrine “The Rooker-Feldman doctrine provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoti…
Show 47 more citing cases
  • Reed v. Elder, No. 1:22-cv-02067 (D. Colo. Aug. 19, 2024).
    The Rooker-Feldman Doctrine (Claim 6) “The Rooker-Feldman doctrine provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169, 1173 (10th Cir. 20…
  • Heneck (ID 112732) v. Corby, No. 5:23-cv-03166 (D. Kan. Sept. 29, 2023).
    “[O]nly the Supreme Court has jurisdiction to hear appeals from final state court judgments”
  • Johnson (ID 79020) v. Wyandotte Cnty. Dist. Court, No. 5:23-cv-03185 (D. Kan. Aug. 1, 2023).
    Federal district courts do not have jurisdiction to review state court judgments or claims inextricably intertwined with them.” Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006) (citation omitted). * * * * Even if Johnson could overcome t…
  • Prentice v. Yocum, No. 22-01013 (Bankr. W.D. Okla. Apr. 13, 2023).
    Okla. Sept. 24, 2018) (citing Bear v. Patton, 451 F.3d 639, 641 (10" Cir. 2006)).
  • Medina v. Allen, No. 4:21-cv-00102 (D. Utah Mar. 31, 2023).
    Rooker-Feldman Doctrine “The Rooker-Feldman doctrine arose out of [ 28 U.S.C. § 1257 (a)].”69 The 10th Circuit “agreed with several of [the] sister circuits…that ‘Rooker-Feldman applies only to suits filed after state proceedings are final…
  • El-Bey v. Lambdin, No. 1:22-cv-00682 (D. Colo. Feb. 23, 2023).
    The Rooker-Feldman Doctrine “The Rooker-Feldman doctrine provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoti…
  • McRae v. JPMorgan Chase & Co, No. 1:21-cv-01706 (D. Colo. Feb. 3, 2023).
    The Rooker-Feldman Doctrine “The Rooker-Feldman doctrine provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoti…
  • Chamberlain v. Crown Asset Mgmt., 608 F. Supp. 3d 1091 (D. Utah 2022).published
    “[f]ederal district courts do not have jurisdiction to review state court judgments or claims inextricably intertwined with them”
  • Blake v. Santistevan, No. 1:22-cv-00093 (D.N.M. Feb. 14, 2022).
    By statute, the Tenth Circuit has “jurisdiction [over] appeals from all final decisions of the district courts of the United States.” 28 U.S.C. § 1291 (emphasis added). “[O]nly the [United States] Supreme Court has jurisdiction to hear app…
  • Fiscus v. Salazar, No. 6:21-cv-01127 (D. Kan. Sept. 16, 2021).
    “Where [the] plaintiff claims that but for the judgment in state court, []he would not have suffered the injury for which []he seeks redress in federal court, Rooker-Feldman bars the 11 Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006). 1…
  • Lowery v. Kansas, State of, No. 5:20-cv-03266 (D. Kan. June 11, 2021).
    “[O]nly the Supreme Court has jurisdiction to hear appeals from final state court judgments”
  • Gerlich v. Barwick, No. 19-01060 (Bankr. W.D. Okla. Mar. 4, 2021).
    Sept. 24, 2018) (citing Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006)).
  • Hobbs v. Kansas Dep't for Child. & Families, No. 6:19-cv-01307 (D. Kan. Feb. 1, 2021).
    Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006).
  • Curry v. St. Francis Hosp., No. 4:20-cv-00673 (N.D. Okla. Dec. 28, 2020).
    “federal district courts do not have jurisdiction to review state court judgments or claims inextricably 2 intertwined with them”
  • Johnson v. Schmidt, 838 F. App'x 319 (10th Cir. 2020).unpublished
    Federal district courts do not have jurisdiction to review state court judgments or claims inextricably intertwined with them.” Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006) (citation omitted).
  • Sweat v. Montoya, No. 1:20-cv-00254 (D.N.M. Aug. 27, 2020).
    DISCUSSION “The Rooker-Feldman doctrine ... provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169 , 2 1173 (10th Cir. 2018) (quoting Bear v.…
  • Arndt v. Hatfield, No. 5:20-cv-00181 (W.D. Okla. Aug. 20, 2020). 2 cites
    Pass-Through Certificates, Series 2006-4, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoting Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006)).
  • Kirchner v. Marshall, No. 1:20-cv-00114 (D. Colo. Aug. 10, 2020).
    Pass-Through Certificates, Series 2006-4, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoting Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006)).
  • Sweat v. Montoya, No. 1:20-cv-00254 (D.N.M. July 24, 2020).
    Rooker-Feldman and Jurisdiction “The Rooker-Feldman doctrine ... provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments.” Mayotte v. U.S. Bank Nat’l Ass’n, 880 F.3d 1169, 1173 (10th Cir. 2018…
  • Wilson v. Bimestefer, No. 1:19-cv-01633 (D. Colo. May 22, 2020).
    Pass-Through Certificates, Series 2006-4, 880 F.3d 1169, 1173 (10th Cir. 2018) (quoting Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006)).
  • Green v. Kansas City Juv. Court, No. 2:19-cv-02359 (D. Kan. Sept. 6, 2019).
    The Rooker-Feldman doctrine expressly bars federal district courts from reviewing state court decisions because only the Supreme Court has jurisdiction to hear appeals from final state court judgments.1 Bear v. Patton, 451 F.3d 639, 641 (1…
  • Anderson v. Herbert, No. 17-4200 (10th Cir. Aug. 2, 2018).unpublished
    Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006). 4 II.
  • Lundahl v. Home Depot, Inc., 594 F. App'x 453 (10th Cir. 2014).unpublished
    “The Rooker-Feldman doctrine arose out of [ 28 U.S.C. § 1257 (a) ], and provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments”
  • Polaski v. Colorado Dep't of Transp., 198 F. App'x 684 (10th Cir. 2006).unpublished
  • Suasnavas v. Stover, 196 F. App'x 647 (10th Cir. 2006).unpublished
  • Ramsey v. McCutcheon, 200 F. App'x 760 (10th Cir. 2006).unpublished
  • Roberts v. O'Bannon, 199 F. App'x 711 (10th Cir. 2006).unpublished
  • Jenkins v. MTGLQ Investors, 218 F. App'x 719 (10th Cir. 2007).unpublished
  • United States v. Olmos-Rodriguez, 219 F. App'x 780 (10th Cir. 2007).unpublished
  • United States v. Guerrero-Cota, 247 F. App'x 136 (10th Cir. 2007).unpublished
  • United States v. Rayas, 322 F. App'x 618 (10th Cir. 2009).unpublished
  • United States v. Strasser, 502 F. App'x 736 (10th Cir. 2012).unpublished
  • Arocho v. United States, 502 F. App'x 730 (10th Cir. 2012).unpublished
  • Crosby v. Martin, 502 F. App'x 733 (10th Cir. 2012).unpublished
  • Lamar v. Boyd, 508 F. App'x 711 (10th Cir. 2013).unpublished
  • Cook v. Baca, 512 F. App'x 810 (10th Cir. 2013).unpublished
  • In Re Mccraney, 439 B.R. 188 (Bankr. D.N.M. 2010).published
  • JP Morgan Trust Co. v. Mid-Am. Pipeline Co., 473 F. Supp. 2d 1162 (D. Kan. 2007).published
  • Reed, Jr. v. Michaud, 498 F. App'x 767 (10th Cir. 2012).unpublished
  • Fuller v. Davis, 594 F. App'x 935 (10th Cir. 2014).unpublished
  • Cooley v. Town of Kiowa, 699 F. App'x 826 (10th Cir. 2017).unpublished
  • Agrawal v. Ogden, No. 18-6054 (10th Cir. Nov. 28, 2018).unpublished
  • McCraney v. High Desert Neurology, Inc. (In re McCraney), 439 B.R. 188 (Bankr. D.N.M. 2010).published
  • Davis (ID 83253) v. Schnurr, No. 5:19-cv-03062 (D. Kan. Feb. 26, 2020).
  • Vaughan (ID 43021) v. Miller, No. 5:20-cv-03010 (D. Kan. Apr. 28, 2020).
  • Johnson (ID 79020) v. Schmidt, No. 5:20-cv-03017 (D. Kan. July 24, 2020).
  • Lee v. Schnurr, No. 5:20-cv-03231 (D. Kan. Nov. 16, 2020).
At page 642 Defining when state proceedings end for Rooker-Feldman26 citing cases“a federal claim is inextricably intertwined with a state-court judgment if that judgment caused, actually and proximately, the injury for which the federal-court plaintiff seeks redress.”3 citing courts quote it
  • Viegas, No. 1:25-cv-03666 (D. Colo. Sept. 23, 2026).
    (the relevant inquiry [for Rooker-Feldman] is whether, at the time the federal action was filed, the [state court] judgment . . . was final and appealable under [state] law and, if so, whether [plaintiff’s] time for tak…)
  • Viegas v. Partner Colorado Credit Union, No. 1:24-cv-00415 (D. Colo. Jan. 31, 2025). 2 cites
    See also Bear, 451 F.3d at 643 (“Furthermore, if the district court determines that the judgment was not final and, therefore, that Rooker– Feldman does not apply, it can consider the alternate bases for dismissal urged by Judge Patton, na…
  • Hunter v. Hirsig, 660 F. App'x 711 (10th Cir. 2016).unpublished
    ([I]f a lower state court issues a judgment and the losing party allows the time for appeal to expire, then the state proceedings have ended.)
  • Oluma v. Oluma-Cervantes, No. 2:25-cv-00114 (D. Utah Sept. 29, 2025).
    “if a lower state court issues a judgment and the losing party allows the time for appeal to expire, then the state proceedings have ended.”
  • New Cingular Wireless PCS, LLC v. MJF 2801 Jay RD Dev. LLC, No. 1:25-cv-03565 (D. Colo. Aug. 18, 2026).
    Mar. 19, 2012) (quoting Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006)).
  • Hinkley, No. 2:26-cv-00035 (D. Utah Feb. 25, 2026). 2 cites
    Bear v. Patton, 451 F.3d 639, 641 (10th Cir. 2006).
  • Davis v. Banks, No. 6:24-cv-00330 (E.D. Okla. July 1, 2025).
    Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006) (quotation omitted) (“A federal claim is inextricably intertwined with a state-court judgment if that judgment caused, actually and proximately, the injury for which the federal-court plai…
  • Saul v. MTGLQ Investors, LP, No. 1:24-cv-01247 (D.N.M. June 17, 2025).
    “[T]he purpose of the bar is to prevent a state court litigant from circumventing the appellate structure established by 28 U.S.C. § 1257 (a)”
  • Weber v. State of Colorado, The, No. 1:24-cv-02880 (D. Colo. Dec. 27, 2024).
    Dauwe v. Miller, 364 F. App’x 435, 437 (10th Cir. 2010) (unpublished) (citing Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006)).
  • Allen v. Saint Francis Ministries, No. 6:23-cv-01166, 2024 WL 2831606 (D. Kan. June 4, 2024).
    “A federal claim is inextricably intertwined with a state-court judgment if that judgment caused, actually and proximately, the injury for which the federal-court plaintiff seeks redress”
Show 16 more citing cases
  • Egbune v. Baum, No. 1:23-cv-02830, 2024 WL 1374905 (D. Colo. Apr. 1, 2024).
    Dauwe v. Miller, 364 F. App’x 435, 437 (10th Cir. 2010) (unpublished) (citing Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006)).
  • Almendarez v. City of Coppell, No. 3:23-cv-01160 (N.D. Tex. Mar. 6, 2024). 3 cites
    “if a lower state court issues a judgment and the losing party allows the time for appeal to expire”
  • Nunu v. State of Texas, No. 21-20446 (5th Cir. Mar. 17, 2022).unpublished
    Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006); accord Moore v. Tex. Ct. of Crim. Appeals, 561 F. App’x 427, 431 (5th Cir. 2014).
  • Env't Dimensions, Inc. v. EnergySolutions Gov't Grp., Inc., No. 1:16-cv-01056 (D.N.M. Mar. 18, 2021).
    “A federal claim is inextricably intertwined with a state-court judgment if that judgment ‘caused, actually and proximately, the injury for which the federal-court plaintiff seeks redress”
  • Telos Ventures Grp. PLLC v. Short, No. 20-02027 (Bankr. D. Utah Oct. 30, 2020). 2 cites
    Applying these standards to the Debtor’s Counterclaims, the Court finds that they are sufficiently final for Rooker-Feldman to apply. 21 Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006). 22 Guttman, 446 F.3d at 1032 n. 2 (quoting Federac…
  • Rocky Mountain Gun Owners v. Williams, 671 F. App'x 1021 (10th Cir. 2016).unpublished
    Bear v. Patton, 451 F.3d 639, 642 (10th Cir. 2006).
  • Veasley v. Fed. Nat'l Mortg. Ass'n, 623 F. App'x 290 (6th Cir. 2015).unpublished
    Credit Union, 546 Fed.Appx. 854, 857 (11th Cir.2013) (citing Nicholson v. Shafe, 558 F.3d 1266, 1275 (11th Cir. 2009)); Sheriff v. Accelerated Receivables Solutions, Inc., 283 Fed.Appx. 602, 606 (10th Cir.2008) (“[S]tate proceedings are fi…
  • Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009).published
  • Wallin v. Arapahoe Cnty., No. 06-1373 (10th Cir. July 27, 2007).unpublished
  • Sheriff v. Accelerated Receivables Solutions, Inc., 283 F. App'x 602 (10th Cir. 2008).unpublished
  • Dauwe v. Miller, 364 F. App'x 435 (10th Cir. 2010).unpublished
  • Adams v. EMC Mortg. Corp., 549 F. App'x 718 (10th Cir. 2013).unpublished
  • Carvana v. MFG Fin., Inc., 547 F. Supp. 2d 1219 (D. Utah 2008).published
  • Wallin v. Arapahoe Cnty. Det. Facility, 244 F. App'x 214 (10th Cir. 2007).unpublished
  • Marshall v. Bacon, No. 24-2076 (10th Cir. Feb. 3, 2025).unpublished
  • Fisk, No. 6:25-cv-00260 (E.D. Okla. May 4, 2026).
At page 643 Furthermore, if the district court determines that the judgment was not final and, therefore, that Rooker– Feldman does not apply, it can consider the alternate bases for dismissal urged by Judge Patton, namely, abstention under Younger v. Harris2 citing cases1 citing court put it this way
  • Viegas v. Partner Colorado Credit Union, No. 1:24-cv-00415 (D. Colo. Jan. 31, 2025). 2 cites
    (Furthermore, if the district court determines that the judgment was not final and, therefore, that Rooker– Feldman does not apply, it can consider the alternate bases for dismissal urged by Judge Patton, namely, absten…)
  • Cowan v. Hunter, No. 18-5024 (10th Cir. Feb. 1, 2019).unpublished
    “we note that rooker-feldman does not apply in the habeas context because congress has authorized federal district courts to review state prisoners' petitions.”
Nancy BEAR, Plaintiff-Appellant,
v.
James A. PATTON, in His Official Capacity as Judge of the District Court of Brown County, Kansas, Defendant-Appellee
05-3183.
Court of Appeals for the Tenth Circuit.
Jun 20, 2006.
Published opinion
451 F.3d 639
2006 U.S. App. LEXIS 15156
2006 WL 1681347
Submitted on the briefs: Nancy Bear, Pro Se, Appellant., Phill Kline, Attorney General, Steve Phillips, Assistant Attorney General, Office of the Attorney General, Topeka, KS, for Defendant-Appellee.
Lucero, Anderson, Brorby.
Cited by 84 opinions  |  Published
2 passages pin-cited by 2 cases
Pinpoint authority: bottom 89%
Citer courts: Tenth Circuit (1) · D. Utah (1)
BRORBY, Circuit Judge.

Plaintiff Nancy Bear appeals from the district court’s order dismissing her civil action for lack of subject matter jurisdic[*640] tion pursuant to Rooker v. Fidelity Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 103 S.Ct. 1303, 75 L.Ed.2d 206 (1983) (together, Rooker-Feldman). We have jurisdiction pursuant to 28 U.S.C. § 1291, and we vacate the district court’s judgment and remand for further proceedings. *

I. Background

Nancy Bear is an enrolled member of the Kickapoo Tribe and lives on the Tribe’s reservation in Kansas. She filed this action seeking declaratory and injunc-tive relief against defendant James A. Patton in his official capacity as Judge of the District Court of Brown County, Kansas. Judge Patton presided over civil action No. 02-C-61, Kathy Ann Bradley, et al. v. Nancy Sue Bear, et al. The plaintiffs in that state action brought two claims against Bear. Count I requested a decree dissolving a partnership of which Bear was a member and an accounting that would divide the partnership assets. Count II sought a partition of property owned by the partnership. On December 10, 2003, after a trial to court, Judge Patton filed a journal entry in which he ordered that “[p]ursuant to K.S.A. [§ ] 60-254(b) final judgment should be entered on Count II of plaintiffs’ Petition (For Partition).” [1] R., doc. 3, unlabeled ex. at 103. In the journal entry, Judge Patton ordered a partition of certain real estate and personal property owned by the partnership. On June 15, 2004, a sheriffs sale was held and the property sold. See id. at 182-86. Also on that date, Bear filed a motion to dismiss the case, arguing that the court lacked subject matter jurisdiction over the real estate and personal property at issue because it was on Indian land.

On July 9, 2004, Bear filed her complaint in this action, requesting a variety of declaratory relief, including that Judge “Patton’s assumption of jurisdiction over Plaintiff Bear’s deeded lands on the Kickapoo Reservation violated federal law and his order to liquidate said lands issued in said case is ... null and void.” Id., doc. 1 at 9. She also seeks injunctive relief prohibiting Judge Patton from issuing or enforcing any further orders, judgments, or decrees regarding her or any of her deeded lands on the Kickapoo Reservation.

Judge Patton, who had not yet ruled on Bear’s motion to dismiss, stayed the case before him sua sponte pending the resolution of this action. He filed a motion to dismiss that the district court granted based on lack of subject matter jurisdiction[*641] under the Rooker-Feldman doctrine. [2] The court concluded that “the relief Bear requests ... is not separable from and collateral to [the state-court case], for Bear in essence seeks an order from this Court vacating Judge Patton’s decisions. Therefore, Bear’s claim is inextricably intertwined with the state court’s decision, and this Court cannot exercise jurisdiction.” Id., doc. 10 at 4 (footnote omitted). This appeal followed.

II. Discussion

We review de novo a district court’s dismissal of a complaint for lack of subject matter jurisdiction. Kiowa Indian Tribe of Okla. v. Hoover, 150 F.3d 1163, 1165 (10th Cir.1998). Because Bear appears pro se, we review her pleadings and other papers liberally and hold them to a less stringent standard than those drafted by attorneys. See Haines v. Kerner, 404 U.S. 519, 520, 92 S.Ct. 594, 30 L.Ed.2d 652 (1972); Hall v. Bellmon, 935 F.2d 1106, 1110 & n. 3 (10th Cir.1991). [3]

Under 28 U.S.C. § 1257(a), “fflinal judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court by writ of certiorari.” The Rooker-Feldman doctrine arose out of this statute, and provides that only the Supreme Court has jurisdiction to hear appeals from final state court judgments. See Guttman v. Khalsa, 446 F.3d 1027, 1031 (10th Cir.2006). Federal district courts do not have jurisdiction to review state court judgments or claims inextricably intertwined with them. Id.

At the time the district court dismissed Bear’s action, the law of this circuit was that the Rooker-Feldman doctrine applied to “all state-court decisions — final or otherwise.” Kenmen Eng’g v. City of Union, 314 F.3d 468, 475 (10th Cir.2002). However, just one week prior to the district court’s dismissal of this case, the Supreme Court held that “[t]he Rooker-Feldman doctrine ... is confined to ... 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, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005). The Court further explained that, in both Rooker and Feldman, “the losing party in state court filed suit in federal court after the state proceedings ended.” Id. at 291, 125 S.Ct. 1517 (emphasis added). Accordingly, Exxon Mobil reverses our holding in Kenmen that Rooker-Feldman applies to “all state-court decisions — final or otherwise.” See Guttman, 446 F.3d at 1031. [4]

We recently agreed with several of our sister circuits that “after the state proceedings ended” means that “Rooker-Feld [*642] man applies only to suits filed after state proceedings are final.” Id. at 1032 (citing Federacion de Maestros de Puerto Rico v. Junta de Relaciones del Trabajo de Puerto Rico, 410 F.3d 17, 24-25 (1st Cir.2005); Hoblock v. Albany County Bd. of Elections, 422 F.3d 77, 89 (2d Cir.2005); Dornheim v. Sholes, 430 F.3d 919, 924 (8th Cir.2005); Mothershed v. Justices of the Supreme Court, 410 F.3d 602, 604 n. 1 (9th Cir.2005)). In Guttman, we also cited with approval the First Circuit’s explanation of several situations in which a state-court judgment could be considered final for Rooker-Feldman purposes, one of which is relevant here: “ ‘if the state action has reached a point where neither party seeks further action.’ ” Guttman, 446 F.3d at 1032 n. 2 (quoting Federacion, 410 F.3d at 24).

The present case requires us to go one step further than was necessary in Guttman and hold that “if a lower state court issues a judgment and the losing party allows the time for appeal to expire, then the state proceedings have ended.” Federacion, 410 F.3d at 24. Accordingly, Rooker-Feldman applies as to that judgment and any claims inextricably intertwined with it. Under this view of Rook-er-Feldman, the relevant inquiry in this case is whether, at the time the federal action was filed, the judgment on Count II that Judge Patton issued pursuant to Kan. Stat. Ann. § 60-254(b) was final and ap-pealable under Kansas law and, if so, whether Bear’s time for taking an appeal had run.

Although the state proceedings have not “ended” in a general sense because the accounting and distribution of the proceeds of the sheriffs sale remain, a final judgment on Count II that was no longer ap-pealable would have invoked Rooker-Feldman’s jurisdictional bar for two reasons. First, the purpose of the bar is to prevent a state court litigant from circumventing the appellate structure established by 28 U.S.C. § 1257(a). See Rooker, 263 U.S. at 416, 44 S.Ct. 149 (explaining that, after the period for appeal to the Supreme Court lapses, “an aggrieved litigant cannot be permitted to do indirectly what he no longer can do directly” by filing an action in a federal district court). Merely allowing to elapse the time for an appeal from a final, appealable judgment on one of multiple claims, then filing an action in a federal district court attacking the state court’s jurisdiction to enter that judgment, would do just that.

The second reason a final judgment on Count II would have invoked the Rook-er-Feldman bar is that Bear’s request for prospective declaratory and injunctive relief is inextricably intertwined with it. A federal claim is inextricably intertwined with a state-court judgment if that judgment “caused, actually and proximately, the injury for which the federal-court plaintiff seeks redress.” Kenmen Eng’g, 314 F.3d at 476 (footnote omitted), abrogated on other grounds by Exxon Mobil, 544 U.S. 280, 125 S.Ct. 1517, 161 L.Ed.2d 454. As noted above, in the Count II judgment, Judge Patton concluded that the partnership assets should be partitioned and ordered the sheriffs sale. Thus, the judgment is the cause of the prospective injury Bear seeks to enjoin— an accounting and division of partnership assets under Count I—and the prospective relief she seeks in her federal claim is, therefore, inextricably intertwined with it. Absent the adverse judgment on Count II, Bear would have no basis, and perhaps no reason, to challenge prospectively Judge Patton’s jurisdiction to enter orders on Count I.

We decline to address in the first instance whether the Count II judgment was final under Kansas law when Bear[*643] filed this action. The district court is in a better position to accept argument from the parties, make factual findings or take evidence if necessary, and resolve the issue. Furthermore, if the district court determines that the judgment was not final and, therefore, that Rooker-Feldman does not apply, it can consider the alternate bases for dismissal urged by Judge Patton, namely, abstention under Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746, 27 L.Ed.2d 669 (1971), and the discretion a district court has to decline to exercise jurisdiction under the Declaratory Judgment Act, 28 U.S.C. § 2201(a). [5]

III. Conclusion

In view of the foregoing, the judgment of the district court is VACATED and the case is remanded for further proceedings consistent with this opinion.

*

After examining the briefs and appellate record, this panel has determined unanimously to grant the parties’ request for a decision on the briefs without oral argument. See Fed. R.App. P. 34(f); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument.

1

. Kan. Stat. Ann. § 60-254(b) reads as follows;

(b) Judgment upon multiple claims. When more than one claim for relief is presented in an action, whether as a claim, counterclaim, cross-claim or third-party claim or, when multiple parties are involved, the court may direct the entry of a final judgment as to one or more but fewer than all of the claims or parties only upon an express determination that there is no just reason for delay and upon an express direction for the entry of judgment. In the absence of such determination and direction, any order or other form of decision, however designated, which adjudicates fewer than all the claims or the rights and liabilities of fewer than all the parties shall not terminate the action as to any of the claims or parties, and the order or other form of decision is subject to revision at any time before the entry of judgment adjudicating all the claims and the rights and liabilities of all the parties.
2

. As discussed more fully below, the Rooker-Feldman doctrine divests federal district courts of subject matter jurisdiction over claims that seek, in substance, appellate review of final state-court judgments.

3

. Judge Patton suggests that we should not grant Bear the deference ordinarily afforded to pro se litigants because, upon information and belief, he asserts that she received assistance from her attorneys in drafting her appellate brief. Although her brief appears to be consistent with briefs traditionally associated with attorneys and she was represented by counsel in the district court, we are obliged to construe her brief liberally in the absence of evidence that it was prepared with the assistance of an attorney.

4

.We note that Rooker-Feldman does not apply in the habeas context because Congress has authorized federal district courts to review state prisoners’ petitions. See Exxon Mobil Corp., 544 U.S. at 292, 125 S.Ct. 1517 n. 8 (citing 28 U.S.C. § 2254(a)).

5

. Although we do not reach the issue of Younger abstention, we note that it appears one of its essential predicates, the presence of an ongoing proceeding, may be absent here. See Southwest Air Ambulance, Inc. v. City of Las Cruces, 268 F.3d 1162, 1178 (10th Cir.2001) (holding Younger abstention inappropriate where a municipal court stayed a criminal proceeding sua sponte in favor of federal resolution of the issues).