Reiter v. Washington Mutual Bank

Summarized by Colin Robinson , Pachulski Stang Ziehl & Jones LLP
14 years 4 months ago

Citation:

No. 11-2968 (3d Cir. October 26, 2011)

Tag(s):

Ruling:

The Rooker-Feldman doctrine prevents lower federal courts from excercising jurisdiction over cases filed by unsuccessful state court litigants challenging state court judgments issued prior to the initiaion of federal court litigation. The Rooker-Feldman doctrine is applied where: (1) the federal plaintiff lost in state court; (2) the plaintiff complains of injuires caused by state court judgments; (3) those judgments were rendered before the federal suit was filed; and (4) the plaintiff is inviting the district court to review and reject the state court judgments. In its ruling, the Third Circuit noted that the second and fourth requirements are key to determining whether a federal suit contains an independent, non-barred claim. The Third Circuit agreed with the District Court's decision that it lacked subject matter jurisdiction as the appellant sought federal court review of an adverse state court judgment that was rendered piro to the filing of the appellants federal suit. While understanding of the appellants apparent confusion over appropriate procedural steps to appeal the adverse state court judgment, the Third Circuit held that the appellant failed to avail himself of available appeals in the state court. The Third Circuit did take issue with the District Court's reasoning that Rooker-Feldman applied because the appellants constitutional claims were "inextricably intertwined" with the state court judgment. The Third Circuit noted that the District Court's application of the "inextricably intertwined" criteria was either incorrect or unnecessary.

Procedural context:

The Third Circuit affirmed the District Court for the Eastern District of Pennsylvania's dismissal of suit for lack of subject matter jurisdiction over claim challenging and inviting federal court review of an adverse state court judgment rendered prior to initiation of federal civil litigation.

Facts:

Appellant/plaintiff originally filed suit against lenders and adverse ruling by state court in his mortgage foreclosure proceeding. The original complaint asked the District Court to overturn the state court judgment and for injunctive relief to prevent a pending sheriff's sale. The District Court denied the request for injunctive relief because the Anti-Injunction Act (AIA) prevents federal courts from enjoining state court proceedings unless certain exceptions apply. After the complaint was dismissed, plaintiff was granted leave to file an amended complaint. An amended complaint was filed that reasserted challenges to state court foreclosure proceedings, constitutional challenges to the AIA and noted that the plaintiff had filed a chapter 13 petition. The plaintiff also filed a motion requesting service of the complaint by federal marshall and repeatd his request to enjoin the pending sheriff's sale, which was eventually completed and title transferred. The District Court denied the motion and dismissed the complaint.

Judge(s):

Ambro, Fisher, Nygard (per curiam)

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