Wednesday, August 06, 2008

mortgage foreclosure - Rooker-Feldman Doctrine

Laychock v. Wells Fargo Home Mortgage - ED Pa. - July 23, 2008

The Rooker-Feldman doctrine barred borrower's predatory lending claims in federal court against lender, where lender got default judgment mortgage foreclosure in state court, and state court refused borrower's petition to open judgment.

The Rooker-Feldman Doctrine “prevents ‘inferior’ federal courts from sitting as appellate courts for state court judgments.” In re Knapper, 407 F.3d 573, 580 (3d Cir. 2005). Rooker-Feldman applies when: (1) “the federal claimwas actually litigated in state court prior to the filing of the federal action” or (2) “if the federal claim is inextricably intertwined with the state adjudication.” Id.

A federal and state case are “inextricably intertwined” when “the federal court must take an action thatwould negate the state court’s judgment” orwhen the plaintiff’s sought relief “would prevent a state court from enforcing its orders.” Id. at 581. “If the relief requested in the federal action requires determining that the state court’s decision is wrong or would void the state court’s ruling, then the issues are inextricably intertwined and the district court has no subjectmatter jurisdiction to hear the suit.”

The doctrine is implicated here, because all of plaintiff's claims would require the federal court to find that the state court decision, from which there was no appeal, was wrong.