Gonzalez v. Deutsche Bank National Trust Company, 632 F. App'x 32

Plaintiffs Sonia and Luis Gonzalez (pro se) challenged the foreclosure of their Windsor, CT home, alleging constitutional violations, violations of the U.N. Declaration on the Rights of Indigenous Peoples, and bank fraud against Deutsche Bank and others.
The district court construed the plaintiffs’ post-judgment filing as a motion for reconsideration and dismissed the complaint sua sponte for lack of subject-matter jurisdiction.
No separate Rule 58 judgment was entered; the court of appeals deemed a judgment entered on October 5, 2015, for appeal-timing purposes.
The district court found that many of the Gonzalez claims attacked the state-court foreclosure judgment and thus implicated the Rooker–Feldman doctrine.
Claims not directly attacking the state judgment were held to be barred by Connecticut claim-preclusion principles because the plaintiffs had litigated related claims in state court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal court has jurisdiction to review/relitigate the state foreclosure judgment	Gonzalez contends Deutsche Bank lacked standing and secured title by fraud; seeks federal review/relief	Deutsche Bank argues federal court cannot reopen or review a state-court foreclosure judgment	Rooker–Feldman bars federal review of injuries assertedly caused by an adverse state-court judgment; dismissal affirmed
Whether related claims arising from same transactions (but not directly attacking the judgment) may proceed	Gonzalez asserts additional federal claims arising from the foreclosure transaction	Deutsche Bank argues those claims were or could have been litigated in state court and are precluded	Claims are barred by claim preclusion under Connecticut law; dismissal affirmed
Whether dismissal also should rest on other procedural grounds (failure to state a claim, service, or prosecution)	Gonzalez disputes dismissal on these bases	Deutsche Bank points to procedural defects and prior rulings	Court found it unnecessary to decide these grounds given Rooker–Feldman and claim-preclusion holdings

Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (articulating Rooker–Feldman limits on federal review of state court judgments)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (Rooker–Feldman antecedent)
Rooker v. Fidelity Tr. Co., 263 U.S. 413 (U.S. 1923) (establishing that federal district courts lack authority to review state-court judgments)
Liranzo v. United States, 690 F.3d 78 (2d Cir. 2012) (standard of de novo review for jurisdictional dismissals)
Vossbrinck v. Accredited Home Lenders, Inc., 773 F.3d 423 (2d Cir. 2014) (applying Rooker–Feldman to foreclosure-related fraud claims)
O'Connor v. Pierson, 568 F.3d 64 (2d Cir. 2009) (Connecticut claim-preclusion principles)