Ignacio Damian Figueroa v. Merscorp, Inc.
477 F. App'x 558
11th Cir.2012Background
- Figueroa co-owned property with a mortgage held by MERS; default led IndyMac to sue in state court for foreclosure.
- State court granted summary judgment for IndyMac and entered foreclosure; Figueroa did not respond to the complaint.
- Figueroa moved to vacate the judgment, asserted fraud claims, and stated intent to file a federal RICO counterclaim; the state court denied the motions and sale occurred.
- Three months later, Figueroa filed a federal RICO complaint alleging 3 counts against 27 defendants, seeking treble damages for the lost property interest.
- The district court dismissed the federal action for lack of subject matter jurisdiction under the Rooker-Feldman doctrine; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the federal RICO claims | Figueroa argues his injuries stem from state proceedings and seek federal review. | Defendants contend the state judgment precludes federal review under Rooker-Feldman. | Rooker-Feldman bars the federal claims. |
| Whether Figueroa had a full and fair opportunity to litigate in state court | Figueroa claims he lacked a reasonable opportunity to raise federal RICO claims in state court. | Figueroa had a reasonable opportunity to litigate in state court. | Figueroa had a reasonable opportunity; doctrine applies. |
| Whether the state court proceedings and resulting judgment were inextricably intertwined with the federal claims | Damages were caused by the foreclosure outcome, not the state judgment itself. | The injury is essentially the foreclosure judgment and its effects. | The claims are inextricably intertwined; Rooker-Feldman bars relief. |
Key Cases Cited
- Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009) (Rooker-Feldman applies when the state-court judgment is the basis of the injury)
- Transpetrol, Ltd. v. Radulovic, 764 So.2d 878 (Fla. Dist. Ct. App. 2000) (federal RICO claims may be raised in Florida courts)
- D.C. Court of Appeals v. Feldman, 103 S. Ct. 1303 (1983) (Rooker-Feldman doctrine precludes review of state-court judgments)
- Rooker v. Fid. Trust Co., 44 S. Ct. 149 (1923) (early articulation of the doctrine preventing federal review of state judgments)