Hoang v. Rosen, 8:12-cv-01393

Hoang filed a Chapter 11 petition (later converted) and estates were jointly administered; Rosen appointed Chapter 7 trustee.
Washington Mutual/Quantum sought relief from stay, asserting it held a secured interest and that defaults justified foreclosure.
Order lifting the stay imposed conditions including adequate protection payments and an eventual mortgage payoff.
In 2011, Hoang moved to abandon the residence; the bankruptcy court granted abandonment.
Substitute trustees were appointed (Citi Property Holdings Inc. and others) and filed foreclosure affidavits in state court.
Hoangs filed pro se complaint in district court (2012) seeking to enjoin foreclosure and quiet title, grounding claims in FDCPA and challenge to the note/deed of trust.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FDCPA claims are timely.	Hoang argues FDCPA applies to the defendants.	Defendants contend claims are time-barred.	FDCPA claims dismissed as untimely.
Whether the court should exercise supplemental jurisdiction over state-law claims.	State claims arise from same nucleus of facts.	Federal claims have failed; no compelling basis to retain.	Court declines supplemental jurisdiction over state-law claims.
Whether the complaint should be dismissed for failure to state a claim.	Note/assignment challenges render foreclosure improper.	Foreclosure procedures valid; note validity not properly raised.	Complaint dismissed sua sponte.

Shanaghan v. Cahill, 58 F.3d 106 (4th Cir. 1995) (courts have wide latitude in determining supplemental jurisdiction)
Carnegie-Mellon Univ. v. Cahill, 484 U.S. 343 (1988) (supplemental jurisdiction is flexible and designed to accommodate pendent claims)