Phan v. American Family Insurance Co.
705 F. App'x 766
| 10th Cir. | 2017Background
- In 2012 Phan was injured in a car accident and filed a bodily-injury claim with American Family, which rejected the claim.
- Phan sued American Family in Colorado state court in November 2015, more than three years after the accident.
- The state court dismissed Phan’s suit with prejudice under Colorado’s three-year statute of limitations; Colorado appellate courts affirmed or dismissed his appeals.
- Phan then filed a new action in federal district court alleging state-law insurance violations and ADA claims seeking money damages for the same 2012 injuries.
- The district court dismissed for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine and denied Phan IFP on appeal as the appeal was not taken in good faith.
- Phan appealed; the Tenth Circuit reviewed de novo and affirmed dismissal and denial of IFP.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has jurisdiction over claims that seek relief from a prior state-court judgment (Rooker–Feldman) | Phan contends federal court may hear his claims despite the state judgment; he seeks relief on same injury | American Family argues Phan is a "state-court loser" and his federal suit would require reviewing/rejecting the state-court judgment | Court: Rooker–Feldman bars jurisdiction because Phan's claims are inextricably intertwined with the prior state-court judgment |
| Whether supplemental jurisdiction or other doctrines permit review | Phan argues supplemental jurisdiction could allow federal consideration | American Family argues supplemental jurisdiction cannot overcome Rooker–Feldman bar | Court: Supplemental jurisdiction does not overcome Rooker–Feldman; jurisdictional bar stands |
| Whether Erie, Supremacy Clause, or Equal Protection override Rooker–Feldman | Phan asserts these doctrines provide a basis for federal jurisdiction | American Family contends those doctrines do not authorize lower federal courts to reverse final state judgments | Court: Erie, Supremacy Clause, and Equal Protection do not authorize district courts to review/reverse final state-court judgments; Rooker–Feldman remains controlling |
| Whether Phan may proceed IFP on appeal | Phan sought leave to proceed IFP | Court below argued appeal not taken in good faith; American Family opposed IFP | Court: Denied IFP because Phan failed to present a nonfrivolous argument on the merits |
Key Cases Cited
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (federal district courts cannot review final state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (federal courts lack jurisdiction over certain challenges to state bar-admission decisions and related state judgments)
- Mann v. Boatright, 477 F.3d 1140 (10th Cir. 2007) (explaining when claims are "inextricably intertwined" for Rooker–Feldman)
- Mo’s Express, LLC v. Sopkin, 441 F.3d 1229 (10th Cir. 2006) (Rooker–Feldman prevents district court review of state-court judgments and related claims)
- Lance v. Dennis, 546 U.S. 459 (clarifying scope of Rooker–Feldman doctrine)
- Jones v. United Parcel Serv., Inc., 674 F.3d 1187 (10th Cir. 2012) (describing Erie application: federal procedural law and state substantive law)
- Chamber of Commerce of the U.S. v. Edmondson, 594 F.3d 742 (10th Cir. 2010) (discussing Supremacy Clause and federal preemption)
- SECSYS, LLC v. Vigil, 666 F.3d 678 (10th Cir. 2012) (explaining Equal Protection analytical framework)
- Lister v. Dep’t of Treasury, 408 F.3d 1309 (10th Cir. 2005) (IFP requires nonfrivolous argument on law and facts)