Magritz v. Ozaukee County
894 F. Supp. 2d 34
D.D.C.2012Background
- Magrizt sues 43 defendants in DC federal court over a Wisconsin foreclosure of land from 2001.
- Plaintiff’s claims allege violations of federal and Wisconsin constitutions regarding taking without just compensation.
- Wisconsin foreclosure judgment and related actions underpin the dispute; prior federal litigation in 2007-2009 dismissed as barred by Rooker-Feldman.
- A 2011 Ozaukee County injunction prohibited further harassment by plaintiff toward county employees.
- Defendants move to dismiss arguing lack of jurisdiction under Rooker-Feldman, improper venue/personal jurisdiction, statute of limitations, and immunities; plaintiff did not respond substantively.
- Court sua sponte reviews and grants motions to dismiss for lack of subject-matter jurisdiction under Rooker-Feldman; other grounds are not reached.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court has subject-matter jurisdiction. | Magrizt contends federal review available for his claims. | Defendants argue RF doctrine bars federal review of state-court foreclosure judgment. | Lack of jurisdiction under Rooker-Feldman; dismiss. |
| Whether other grounds support dismissal (venue, immunity, limitations). | Reserved rights; no substantive response. | Venue, statute of limitations, Eleventh/official immunity apply. | Court declines to address after RF ruling; grants dismissal on RF grounds. |
Key Cases Cited
- Gray v. Poole, 275 F.3d 1113 (D.C. Cir. 2002) (RF doctrine bars federal review of state-court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (defines RF doctrine scope and confines to state-court judgments)
- D.C. Ct. App. v. Feldman, 460 U.S. 462 (U.S. 1983) (origin of Rooker–Feldman principle)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (early RF doctrine foundations)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (U.S. 1994) (subject-matter jurisdiction as threshold issue)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (plaintiff bears burden to show jurisdiction)
- Evans v. Suter, 2010 WL 1632902 (D.C. Cir. 2010) (court may dismiss sua sponte for lack of jurisdiction)