769 F. Supp. 2d 584
S.D.N.Y.2011Background
- Corines seeks declaratory judgment that he is entitled to disability benefits dating from February 4, 1999 and a refund of premiums paid since that date.
- Defendants move to dismiss for lack of subject matter jurisdiction under Rooker-Feldman or, alternatively, for claim preclusion; Corines moves to strike statements in the defendants' declaration under Rule 12(f).
- Corines previously litigated related claims in New York state court arising from the same policy and period of alleged disability.
- The policy at issue was under Continental and later transferred to Hartford; Corines admitted working after the alleged disability and after license revocation.
- The court ultimately grants summary judgment on claim preclusion grounds, dismissing Corines’ action; the motion to strike is denied as moot or meritless.
- The subsequent briefing includes a consolidated reconsideration motion, which the court also denies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman deprives federal jurisdiction | Corines argues state-court loss precludes federal review | Defendants contend state judgment forecloses the federal action | Rooker-Feldman does not require dismissal; jurisdiction exists under 28 U.S.C. §1332 |
| Whether claim preclusion bars the action | Corines argues separate bases for relief exist | Continental policy and prior state action preclude relitigation | Yes, claim preclusion bars the present action as a matter of law |
| Whether refund-of-premiums claim is barred by preclusion | Corines could have sought refunds in state court | Refund claim arises from the same transaction | Yes, barred by claim preclusion |
| Whether dismissal should be treated as summary judgment due to affidavits outside pleadings | Plaintiff challenges consideration under Rule 12(b)(6) | Court may treat as summary judgment if outside materials used | Summary judgment proper; claims dismissed |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (origin of Rooker-Feldman doctrine)
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (limits federal review of state-court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (limits application of Rooker-Feldman to pre-state judgments)
- Hoblock v. Albany County Bd. Of Elections, 422 F.3d 77 (2d Cir. 2005) (four-factor test for Rooker-Feldman applicability)
- Maharaj v. Bankamerica Corp., 128 F.3d 94 (2d Cir. 1997) (describes claim preclusion principles)