CA11: § 1983 case can’t be used as substitute for state court appeal of a 4A claim

“Mr. Lynn does not raise a non-frivolous issue for appeal. Below, the District Court granted summary judgment to the defendant officers because it concluded Mr. Lynn’s Fourth Amendment claims were barred by the Rooker-Feldman1 doctrine. … [¶] The District Court rightly concluded that Mr. Lynn’s Fourth Amendment claims are inextricably intertwined with the state court judgment in his criminal case. After his arrest by the defendant officers, Mr. Lynn was tried and convicted of various drug offenses and a firearms offense in state court. Before trial, Mr. Lynn sought to suppress the fruits of the search of his hotel room and the recording of his phone call. The trial court denied this motion and overruled Mr. Lynn’s later objections to the evidence on the grounds that the search was illegal. Thus, ‘[b]ecause the state court did squarely adjudicate the issue of the lawfulness of the search, [Mr. Lynn’s] section 1983 suit is nothing but a prohibited appeal of the state-court judgment.’ See Datz, 51 F.3d at 254. For these reasons, there is no non-frivolous argument that the District Court could have entertained Mr. Lynn’s § 1983 claims.” Lynn v. Quinn, 2020 U.S. App. LEXIS 5038 (11th Cir. Feb. 18, 2020).