Barnes-Duncan v. Liebner and Potkin, LLC
Civil Action No. 2017-2818
D.D.C.Nov 28, 2018Background
- Plaintiff Donna Barnes-Duncan, proceeding pro se, sued the Estate of Morris Battle and two individuals challenging the foreclosure of her Maryland property and seeking to void the deed.
- The Montgomery County Circuit Court ratified the foreclosure sale in 2012; the Maryland Court of Special Appeals affirmed in 2016 after a long history of related state and bankruptcy litigation.
- Plaintiff reasserted claims of fraud, lack of authority to foreclose, probate-law violations, and statute-of-limitations defenses in federal court after losing in state court.
- Defendants moved to dismiss and sought sanctions; plaintiff sought default judgment. Defendants also argued res judicata, collateral estoppel, and statute-of-limitations defenses.
- The District Court sua sponte examined subject-matter jurisdiction and concluded the Rooker–Feldman doctrine bars federal review of the state-court foreclosure judgment.
- The Court dismissed the complaint for lack of subject-matter jurisdiction under Rule 12(h)(3) and denied pending motions as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the federal court has jurisdiction to hear claims attacking the state-court foreclosure | Barnes-Duncan sought to nullify the foreclosure, alleging fraud, statutory-bar, and lack of authority to foreclose | Federal defendants contended the federal court lacks subject-matter jurisdiction to overturn a final state foreclosure judgment (and raised res judicata, collateral estoppel, SOL) | Dismissed for lack of jurisdiction under Rooker–Feldman: federal court cannot review or reject final state-court foreclosure judgment |
| Whether plaintiff raised independent federal claims separate from the state judgment | Plaintiff reasserted the same theories (fraud, probate violations, statute of limitations) and sought invalidation of the state result | Defendants maintained plaintiff’s claims are the functional equivalent of an appeal of the state judgment | Court held claims were not independent; they were inextricably intertwined with and invited review of the state judgment, so Rooker–Feldman applies |
| Effect of prior state and appellate rulings on motions and remedies in federal court | Plaintiff requested relief (e.g., voiding deed) notwithstanding state rulings | Defendants moved to dismiss and for sanctions; alternatively raised preclusion and SOL defenses | Because of lack of jurisdiction, court dismissed case and denied pending motions as moot; did not reach defendants’ preclusion merits |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (lower federal courts cannot review final state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983) (scope of federal review of state court adjudications)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (limits and scope of Rooker–Feldman)
- Lance v. Dennis, 546 U.S. 459 (2006) (Rooker–Feldman applies when federal suit is by state-court loser seeking review of state judgment)
- Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (when courts must dismiss for lack of subject-matter jurisdiction)