Anyone who watches TV will likely know the concept of double jeopardy, where an individual can’t be tried twice for the same crime. Turns out, there is a similar dynamic with a much less sexy name, the Rooker-Feldman doctrine. One plaintiff’s attempt at suing a mortgage lender for violating the Fair Debt Collection Practices Act has been dismissed by a federal judge in New Jersey because the plaintiff had previously tried and failed to make the same claims in state court.
The background: The plaintiff defaulted on a mortgage loan, which led the defendant to file a foreclosure action in New Jersey state court. During that proceeding, the plaintiff contested the validity of the loan, challenged whether the defendant had standing to foreclose, and asserted counterclaims alleging misconduct under several consumer protection statutes, including the FDCPA, Truth-jn-Lending Act, Real Estate Settlement Procedures Act, and state consumer fraud laws.
- The state court rejected those arguments, granted summary judgment in favor of the defendant, and ultimately entered a final judgment of foreclosure.
- After the foreclosure judgment was entered, the plaintiff filed a new lawsuit in federal court asserting largely the same theories under federal law and seeking to unwind or block the foreclosure.
The ruling: Judge Julien Xavier Neals of the District Court for the District of New Jersey dismissed the case, relying heavily on the Rooker-Feldman doctrine, which bars federal courts from acting as appellate bodies over state court judgments.
- Judge Neals explained that when a plaintiff is effectively complaining about injuries caused by a state court judgment and asking a federal court to undo that judgment, the federal court lacks subject matter jurisdiction to hear the case. As the court noted, federal district courts do not have authority to “review and reject” state court judgments.
- The judge also found that even where the claims were framed as independent statutory violations, they were precluded by res judicata because the same parties had already litigated those issues in state court. In practical terms, the plaintiff was attempting to relabel old foreclosure defenses and counterclaims as fresh federal causes of action, which the court declined to entertain.
