Houston v. Queen

Citation:
Case: 14-30512
Tag(s):
Ruling:
Under Fifth Circuit jurisprudence, the Rooker–Feldman doctrine barred Plaintiffs' action as they were (1) state-court losers; (2) alleging harm caused by a state-court judgment; (3) that was rendered before the district court proceedings began; and (4) requesting review and reversal of the state-court judgment. Carefully parsing the only portion of the doctrine that was arguable in this case - whether the judgment was rendered before the district court proceedings began - the Court ruled that Plaintiffs had not shown that the relevant state proceedings remained ongoing.
Procedural context:
Pro se Plaintiffs–Appellants Michael and Steve Houston appealed the dismissal of their suit for declaratory and injunctive relief arising from an adverse Louisiana state-court judgment of possession. The district court concluded that the Rooker–Feldman doctrine deprived it of subject-matter jurisdiction to entertain their action. Agreeing with the district court that Rooker–Feldman bars the Houstons’ claims, the Fifth Circuit affirmed.
Facts:
Brothers Michael and Steve Houston began litigating with their father's live-in girlfriend over their father and grandfather's wills in 1997. They received an adverse judgment in 2013 but sought writs regarding the amount of the suspensive appeal bond and filed a petition for possession of the Louisiana property in their grandfather's name. Several writs were denied in both cases. Later in 2013, the Houston brothers filed suit in federal court, seeking declaratory and injunctive relief relating to the judgment of possession. The defendants asserted that the Rooker–Feldman doctrine barred Plaintiffs' action.
Judge(s):
Before SMITH, PRADO, and OWEN, Circuit Judges.

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