Elliott-Todd Parker Koger, 24-21081

Isaac Usoroh purchased 515 Kelly Avenue, Pittsburgh, at a sheriff’s sale in August 2022 due to a municipal lien for unpaid taxes by the Koger family.
Title to the property was transferred to Usoroh by sheriff’s deed, but Koger Sr. and his son, Elliott-Todd Parker Koger, refused to relinquish possession.
State court proceedings repeatedly affirmed Usoroh’s superior title and right to possession, with various appeals by the Kogers pending but unsuccessful to date.
After a writ of possession was issued in state court and served on Koger Sr., Elliott Koger filed for Chapter 7 bankruptcy, claiming an ownership interest in the property.
Usoroh sought relief from the automatic stay in bankruptcy to enforce the possession order; the Bankruptcy Court granted relief, finding Koger had no legal or equitable interest in the property.
Koger appealed the order lifting the stay to the District Court, arguing the Bankruptcy Court should have reviewed the merits of the underlying state court decisions.

Issue	Koger's Argument	Usoroh's Argument	Held
Does Koger have a legal or equitable interest in the property?	Koger claimed fee simple ownership via bankruptcy schedules and sought to retain interest.	Usoroh asserted title was conveyed by sheriff's deed post-sale, extinguishing Koger's interest.	Koger has no ownership; interest extinguished by sheriff sale.
Does the Bankruptcy Court have authority to review state court judgments under Rooker-Feldman?	Koger argued bankruptcy court can revisit state court findings.	Usoroh argued federal courts can’t overturn state court judgments.	Rooker-Feldman bars federal re-litigation of state judgments.
Was lifting the automatic stay appropriate under 11 U.S.C. § 362(d)?	Koger opposed the stay's termination, seeking to halt Usoroh’s possession efforts.	Usoroh moved for stay relief to secure the property as permitted by state law.	Stay relief warranted where debtor lacks interest in property.
Did Koger prove any assignment or valid transfer of interest from Koger Sr. to him?	Claimed (without evidence) such transfer existed.	Argued no proof of assignment existed in record.	No cognizable evidence; argument fails.

Rooker v. Fidelity Tr. Co., 263 U.S. 413 (1923) (federal courts cannot review state court judgments)
D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (1983) (reiterates the Rooker-Feldman doctrine)
Lance v. Dennis, 546 U.S. 459 (2006) (clarifies the scope of Rooker-Feldman in federal court limits)
United States v. United States Gypsum Co., 333 U.S. 364 (1948) (clear error review of factual findings)