The Court of Appeals for the Ninth Circuit has overturned a lower court’s ruling in a Fair Debt Collection Practices Act case that has to do with judgments and a legal principal that aims to keep federal courts out of issues that were already dealt with in state court.
The Background: The plaintiffs leased an apartment back in 2005. Five years later, the plaintiffs breached the lease by failing to pay their rent. The owners of the apartment building hired the defendant to sue the plaintiffs in California state court and a default judgment was entered.
- For nine years, the defendant did nothing with the judgment. In 2020, he filed an application to renew the judgment and included more than $5,000 in post-judgment interest and costs, which the plaintiffs did not file an objection to.
- The apartment owners then sought to collect on what was owed to them. The plaintiff tried to prevent the judgment from being executed, claiming she was never served with the underlying lawsuit and that if the funds were taken from her, she would have been robbed of her “chance to live.” The pleas were unsuccessful and the money was levied from the plaintiff’s bank account.
- Just before that, though, the defendant filed an additional memorandum of costs, seeking another $6,000 in interest, costs, and fees. He never applied for a writ to enforce this memorandum.
- The plaintiffs filed suit, alleging the defendant violated the FDCPA. The defendant invoked the Rooker-Feldman Doctrine, which holds that federal courts are not allowed to hear appeals of matters that were originally heard in state court, and a District Court judge granted summary judgment in favor of the defendant.
The Appeal: On appeal, the Ninth Circuit agreed with the plaintiffs that the interpretation of the District Court judge was incorrect. The plaintiff’s FDCPA suit addressed the second memorandum of costs, not the original memorandum.
- Because of that, there is no ruling at the state court level regarding the validity of the costs in the second memorandum, the Appeals Court ruled. The defendant never filed for a writ of execution on the second memorandum so the plaintiffs never had a chance to try and quash it, and a state court judge never had a chance to rule on it.
