94 F. Supp. 3d 73
D. Mass.2015Background
- DuLaurence sues Liberty Mutual and Telegen seeking relief from two Massachusetts final judgments and damages arising from their conduct in state litigation.
- Underlying employment action in Suffolk Superior Court (1995–2004) ended with summary judgment on most claims and a trial verdict on a tortious interference count; Telegen represented Liberty Mutual.
- DuLaurence challenged discovery conduct and requested appellate review; multiple interlocutory appeals were denied; sanctions were assessed against DuLaurence in one appeal.
- Collateral action in 2010 sought to set aside judgments and alleged further misconduct and abuse of process; anti-SLAPP dismissal secured and fees awarded to defendants.
- Massachusetts Appeals Court affirmed the anti-SLAPP ruling and denied further relief; state courts also issued denials on further review, including Supreme Judicial Court certiorari.
- In June 2014, DuLaurence filed this federal action asserting various federal claims and requests to void state judgments; Defendants moved to dismiss and for vexatious-litigation injunctions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the federal court has subject-matter jurisdiction under Rooker-Feldman. | DuLaurence seeks review of state-court judgments. | Defendants contend Rooker-Feldman bars federal review of final state judgments. | Lack of jurisdiction; Rooker-Feldman applies; case dismissed. |
| Whether res judicata/claim or issue preclusion bars claims here. | DuLaurence argues new federal claims and merits should be considered. | Defendants contend prior final state judgments preclude relitigation of the same issues. | Preclusion applies; claims barred. |
| Whether the court should enjoin future vexatious litigation by DuLaurence. | DuLaurence seeks strike/sanctions against defendants rather than injunction. | Defendants request an injunction barring further filings without leave and sanctioning DuLaurence. | Injunction denied; sanctions reserved but not imposed here. |
| Whether the anti-SLAPP ruling and related collateral actions affect the merits of DuLaurence's federal claims. | DuLaurence contends state-court anti-SLAPP rulings were improper and merits should be reviewed. | State-court anti-SLAPP ruling is valid and preclusive; merits should not be revisited. | Collateral-action merits precluded; judgment final in state court precludes federal review. |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (limits district court jurisdiction under Rooker-Feldman)
- Feldman v. District of Columbia Court of Appeals, 460 U.S. 462 (U.S. 1983) (foundational Rooker-Feldman doctrine)
- Lance v. Dennis, 546 U.S. 459 (U.S. 2006) (narrowness of the Rooker-Feldman doctrine)
- Davison v. Gov't of Puerto Rico-Puerto Rico Firefighters Corps., 471 F.3d 220 (1st Cir. 2006) (Rooker-Feldman application in First Circuit)
- Baltimore S.S. Co. v. Phillips, 274 U.S. 316 (U.S. 1927) (final judgment effect and collateral attack limits)
- Alba v. Raytheon, 441 Mass. 836 (Mass. 2004) (scope of issue preclusion in Massachusetts)
- Apparel Art Int’l, Inc. v. Amertex Ent. Ltd., 48 F.3d 576 (1st Cir. 1995) (scope of preclusion by related proceedings)