A District Court judge in Ohio has dismissed every claim in a pro se lawsuit challenging the garnishment of wages on a default judgment more than two decades old, finding the claims either jurisdictionally barred, time-barred, or simply unsupported by facts.
The background: The plaintiff, representing herself, sued a debt buyer, an unnamed law firm, and various unknown state officials, alleging violations of the Fair Debt Collection Practices Act, the Due Process Clause, and state law.
- The dispute traced back to a 2004 default judgment of roughly $5,481 entered against her in an Ohio municipal court on a debt originally owed to another creditor.
- The judgment went dormant and was revived twice, most recently in 2022, before the defendant began garnishing the plaintiff’s wages in January 2023.
- The plaintiff alleged she was never properly served, did not learn of the judgment until 2024, and that the debt was time-barred, void, and unlawfully revived.
- She filed her lawsuit in July 2025. The defendant moved for judgment on the pleadings, and the plaintiff moved to amend her complaint based on what she called newly obtained evidence.
The ruling: Judge Sara Lioi of the District Court for the Northern District of Ohio granted the defendant’s motion and denied the plaintiff’s. She began with the Rooker-Feldman doctrine, which bars federal courts from reviewing state court judgments, noting how rarely it applies. Quoting Sixth Circuit precedent, she observed the doctrine is “so narrow the Supreme Court has applied [it] just twice in nearly a century, making it applicable so far just to people named Rooker or Feldman.” Claims tied to the old judgment itself were barred, though the judge was careful not to sweep in claims about conduct during garnishment.
- The FDCPA claim was time-barred regardless. The one-year clock runs from the date of the violation, not the date of discovery, and the plaintiff sued roughly 18 months after garnishment began. The judge rejected a discovery-rule workaround, citing a concurrence that called the expansive approach “bad wine of recent vintage,” and found no specific facts supporting equitable tolling.
- The claim also failed on the merits. The plaintiff offered only conclusory labels, never pleading facts showing the debt was a consumer debt or that she had made a timely dispute. Because the state court had already found she was properly served and the judgment properly revived, those points could not be relitigated.
- The due process claim failed because the defendant is a private company, not a state actor, and because the plaintiff had received a state court hearing on the garnishment at her own request.
- The motion to amend was denied as futile. The plaintiff’s “newly obtained evidence” was actually the defendant’s own voluntary decision to suspend garnishment and refund collected funds during the litigation. As the judge put it, the judgment “was never declared invalid,” and the state court “never ordered [the defendant] to cease garnishment.” A voluntary refund, in other words, was not the judicial directive the plaintiff believed she had won.
- One wrinkle worth noting: the defendant suggested the plaintiff’s polished filings were the work of an undisclosed non-lawyer “ghostwriter,” a practice federal courts widely condemn. The judge declined to wade in, given that the case was being dismissed in full.
