Kathleen Todd v. United States Bank National As
685 F. App'x 103
| 3rd Cir. | 2017Background
- Plaintiffs (the Schravens and Todd) defaulted on mortgages; Trustee (U.S. Bank) obtained default judgments in Pennsylvania state court and sought sheriff’s sales.
- Default judgments awarded principal, interest, attorney’s fees, foreclosure expenses, and late fees; plaintiffs did not defend and did not move to open or strike judgments.
- Writs of execution were reissued multiple times to include accrued costs and interest through new sale dates; plaintiffs did not challenge the reissued writs in state court.
- Plaintiffs filed a federal class-action asserting breaches of mortgage obligations, Pennsylvania-law claims, and FDCPA violations based on post-judgment attorney’s fees and alleged premature post-judgment interest charges.
- District Court dismissed for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine; the Third Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars federal suit challenging fees/interest in reissued writs | Challenges to post-judgment fees/interest are injuries from enforcement actions, not the state judgment | Plaintiffs’ injuries stem from the default judgments and enforcement writs; federal review would effectively overturn state judgments | Rooker–Feldman applies; federal court lacks jurisdiction |
| Validity of default judgments entered by prothonotary | Prothonotary lacked authority to enter judgments awarding unliquidated attorney’s fees, so judgments are void and excepted from Rooker–Feldman | Pennsylvania rule authorizes prothonotary entries on praecipe; default judgments were valid and not opened in state court | Entry by prothonotary was authorized; alleged state-law errors do not avoid Rooker–Feldman |
| Whether post-judgment writ reissuance creates a new, independent federal claim | Reissued writs (including new fees/interest) cause distinct injuries separable from the judgment | Reissued writs are enforcement of the underlying judgment; harms were produced by the judgment | Harms derived from the judgment; claims are effectively appeals of state judgments and barred |
| Whether any narrow exception applies for judgments void under state law | Plaintiffs urge exception where judgment exceeded state-law authority | Defendants argue exception unsupported and would require federal courts to review/state judgments | Court declined to create such an exception here; plaintiffs’ proposed exception lacks support |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (articulates Rooker–Feldman doctrine barring federal review of state-court judgments)
- Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (sets four-part test for Rooker–Feldman and distinguishes injuries produced by state judgments)
- In re Knapper, 407 F.3d 573 (3d Cir. 2005) (default-judgment-based federal claims barred by Rooker–Feldman because relief would negate state-court judgments)
- Jordan v. Fox, Rothschild, O’Brien & Frankel, 20 F.3d 1250 (3d Cir. 1994) (discusses Pennsylvania judgment procedure and enforcement mechanisms)