Albert Morris v. Wells Fargo Bank
677 F. App'x 955
| 5th Cir. | 2017Background
- Morris defaulted on a home equity loan; Texas state court granted a foreclosure application in October 2006 and later denied Morris’s suit to stop foreclosure.
- A foreclosure sale occurred March 3, 2009; American Home (successor to Option One) purchased the property and a state court later awarded possession to American Home; appellate courts affirmed.
- Morris previously sued in federal court (2009) to set aside the foreclosure; that suit was dismissed under the Rooker–Feldman doctrine and the Fifth Circuit affirmed.
- Morris filed a Petition for Bill of Review in Texas state court to set aside the foreclosure judgment; it was dismissed on summary judgment.
- In 2015 Morris sued Wells Fargo in Texas state court to quiet title and restore possession; Wells Fargo removed to federal court, the district court denied remand and dismissed the case, and Morris appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has subject-matter jurisdiction over a suit seeking to void the 2009 foreclosure and restore title/possession | Morris contends the foreclosure sale and Wells Fargo’s deed are invalid and asks the court to annul the foreclosure and return title/possession | Wells Fargo argued removal was proper (diversity) and federal court may adjudicate the claims | Rooker–Feldman bars jurisdiction: Morris is a state-court loser seeking relief that would overturn prior state judgments; district court lacked subject-matter jurisdiction |
Key Cases Cited
- Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (subject-matter jurisdiction may be raised at any stage)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (Rooker–Feldman confines federal courts from reviewing state-court judgments)
- Union Planters Bank Nat’l Ass’n v. Salih, 369 F.3d 457 (5th Cir. 2004) (explaining Rooker–Feldman as barring federal correction of state judgments)
- Ill. Cent. R.R. Co. v. Guy, 682 F.3d 381 (5th Cir. 2012) (claims “inextricably intertwined” with state judgment trigger Rooker–Feldman)
- Wagner v. United States, 545 F.3d 298 (5th Cir. 2008) (subject-matter jurisdiction reviewed de novo)