- Case Type:
- Consumer
- Case Status:
- Affirmed
- Citation:
- 24-1212 (3rd Circuit, Sep 03,2025) Published
- Tag(s):
-
- Ruling:
- Seeking to clarify the Rooker-Feldman doctrine, the Third Circuit explained that the Rooker-Feldman doctrine applied to preclude federal courts, other than the Supreme Court, from entering any order that could have the effect of invalidating a state court judgment. The district court thus improperly relied on the Rooker-Feldman doctrine to rule that it lacked jurisdiction over a debtor's attempt to overturn a state court judgment. The error, however, was inconsequential because state-law preclusion principles led to the same conclusion—the district court had no jurisdiction over the action.
- Procedural context:
- After the debtor defaulted on a mortgage loan, the putative mortgage lender obtained a foreclosure judgment before the debtor filed a bankruptcy petition. Litigation in bankruptcy and state court continued over the next several years, with the bankruptcy court granting the putative mortgage lender relief from the automatic stay. The debtor appealed. The district court affirmed the bankruptcy court's ruling and then determined that it lacked subject matter jurisdiction over the appeal under the Rooker-Feldman doctrine. The debtor appealed to the Court of Appeals.
- Facts:
- The debtor, Eileen T. Adams, and her husband owned a house that they gave to Eileen's father in 2008. Her father obtained a loan from AmTrust Bank. The loan was secured by a mortgage on the house, and the mortgage was recorded using the MERS system. Eileen's father then passed away, and Eileen regained title to the house, subject to the mortgage.
AmTrust Bank then failed, and the FDIC stepped in to administer the bank's assets. While most of AmTrust's assets were assigned to the New York Community Bank, MERS filed documents showing that the mortgage was assigned to EverBank in November 2013.
In August 2014, EverBank filed a foreclosure complaint.
Eileen initially opposed the foreclosure complaint, but later failed to object to EverBank's motion for summary judgment. The state court granted EverBank's motion in October 2015, and EverBank assigned the mortgage to NationStar Mortgage, although EverBank remained the plaintiff in the foreclosure action.
In March 2017, the state court entered a final judgment against Eileen.
The same day, Eileen and her spouse filed a Chapter 7 bankruptcy petition. Eileen and her husband received a discharge, and the case was closed in September 2017.
In 2018, Eileen filed a Chapter 13 petition, and the bankruptcy court allowed her to challenge the state court foreclosure judgment.
Eileen returned to state court, arguing that EverBank lacked standing to foreclose. By 2020, Eileen had exhausted her state-court challenges.
During this time and for the next several years, the bankruptcy court dismissed Eileen's Chapter 13 case, filed another Chapter 13 case with her husband, and then filed another Chapter 13 petition for herself only.
In the last chapter 13 case, NationStar moved for in rem relief from the automatic stay, which the bankruptcy court granted. Eileen appealed to the district court, which affirmed the bankruptcy court and then dismissed Eileen's appeal for lack of jurisdiction under the Rooker-Feldman doctrine.
- Judge(s):
- BIBAS, PHIPPS, and AMBRO, Circuit Judges
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