Andrew Alexander v. Mary Jo Jensen-Carter, 711 F.3d 905

Two longtime spouses, Ms. Stephens and Mr. Alexander, filed separate bankruptcy petitions; a house in St. Paul is in dispute between their estates and a third-party buyer as executors of the estates.
A quit-claim deed allegedly transferring the house to Stephens and Andrew (recorded 2003) was signed by Alexander before his bankruptcy filing in 1998.
The district and bankruptcy courts repeatedly addressed whether Stephens had an ownership or homestead exemption in the house and whether the house could be sold.
The bankruptcy court and appellate courts ultimately ruled Stephens and Alexander had no ownership or exemption interest and that the house could be sold by the trustee.
On appeal, Stephens challenges the rulings asserting lack of jurisdiction, preclusion effects, and standing doctrines; Andrew’s appeal was dismissed for lack of standing.
The court affirms, holding that Stephens had no interest in the house, Andrew lacks standing to appeal, and Hedback as trustee has standing to protect the estate’s interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Andrew has standing to appeal the bankruptcy ruling.	Andrew contends he has rights as a beneficiary.	Bankruptcy courts dismissed Andrew for lack of standing.	Andrew lacks standing; appeal dismissed.
Whether the bankruptcy court had jurisdiction to evict Stephens.	Stephens asserts jurisdictional flaws and preclusion from eviction.	Court properly exercised jurisdiction and avoided Rooker-Feldman issues.	Bankruptcy court had jurisdiction to evict Stephens.
Whether law-of-the-case precludes challenge to eviction.	Magnuson’s order is law of the case precluding eviction.	Interlocutory nature of prior order prevents law-of-the-case effect.	Law-of-the-case did not bar the later eviction ruling.
Whether res judicata or collateral estoppel bars relief for Stephens.	Previous state/federal decisions foreclose claims to the house.	Holding that prior decisions did not preclude federal eviction.	Res judicata/collateral estoppel do not bar the eviction here.
Whether Hedback has standing as trustee to pursue sale of the house.	Stephens contends lack of standing for Hedback.	Trustee has statutory standing to protect the estate.	Hedback has standing; sale permitted.

Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (Rooker-Feldman concerns preclusion of federal review of state-court judgments)
District of Columbia Ct. of App. v. Feldman, 460 U.S. 462 (U.S. 1983) (Rooker-Feldman applied to preclude federal review of state-court decisions)
Arizona v. California, 460 U.S. 605 (U.S. 1983) (law-of-the-case considerations and state-federal relations)
First Union Nat'l Bank v. Pictet Overseas Trust Corp., 477 F.3d 616 (8th Cir. 2007) (law-of-the-case precedents govern subsequent rulings)
McCuen v. American Cas. Co., 946 F.2d 1401 (8th Cir. 1991) (clear error/manifest injustice standard for jurisdictional questions)
Maristuen v. National States Ins. Co., 57 F.3d 673 (8th Cir. 1995) (interlocutory orders and law-of-the-case considerations in appeals)