Cite as: 512 U. S. 477 (1994)
Opinion of the Court
similar concerns for finality and consistency and has generally declined to expand opportunities for collateral attack, see Parke v. Raley, 506 U. S. 20, 29-30 (1992); Teague v. Lane, 489 U. S. 288, 308 (1989); Rooker v. Fidelity Trust Co.,
standing criminal convictions. Malicious prosecution is an inapt analogy, he says, because "[a] defendant's conviction, under Reconstruction-era common law, dissolved his claim for malicious prosecution because the conviction was regarded as irrebuttable evidence that the prosecution never lacked probable cause." Post, at 496, citing T. Cooley, Law of Torts 185 (1879). Chief Justice Cooley no doubt intended merely to set forth the general rule that a conviction defeated the malicious prosecution plaintiff's allegation (essential to his cause of action) that the prior proceeding was without probable cause. But this was not an absolute rule in all jurisdictions, see Goodrich v. Warner, 21 Conn. 432, 443 (1852); Richter v. Koster, 45 Ind. 440, 441-442 (1874), and early on it was recognized that there must be exceptions to the rule in cases involving circumstances such as fraud, perjury, or mistake of law, see Burt v. Place, 4 Wend. 591 (N. Y. 1830); Witham v. Gowen, 14 Me. 362 (1837); Olson v. Neal, 63 Iowa 214, 18 N. W. 863 (1884). Some cases even held that a "conviction, although it be afterwards reversed, is prima facie evidence—and that only—of the existence of probable cause." Neher v. Dobbs, 41 Neb. 863, 868, 66 N. W. 864, 865 (1896) (collecting cases). In Crescent City Live Stock Co. v. Butchers' Union Slaughter-House Co., 120 U. S. 141 (1887), we recognized that "[h]ow much weight as proof of probable cause shall be attributed to the judgment of the court in the original action, when subsequently reversed for error, may admit of some question." Id., at 149. We attempted to "reconcile the apparent contradiction in the authorities," id., at 151, by observing that the presumption of probable cause arising from a conviction can be rebutted only by showing that the conviction had been obtained by some type of fraud, ibid. Although we ultimately held for the malicious prosecution defendant, our discussion in that case well establishes that the absolute rule Justice Souter contends for did not exist.
Yet even if Justice Souter were correct in asserting that a prior conviction, although reversed, "dissolved [a] claim for malicious prosecution," post, at 496, our analysis would be unaffected. It would simply demonstrate that no common-law action, not even malicious prosecution, would permit a criminal proceeding to be impugned in a tort action, even after the conviction had been reversed. That would, if anything, strengthen our belief that § 1983, which borrowed general tort principles, was not meant to permit such collateral attack.
485
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