618 F. App'x 16
2d Cir.2015Background
- Plaintiff Barbara J. Riley, proceeding pro se, sought a federal declaratory judgment quieting title to a Brooklyn property and removing six alleged clouds on title.
- Riley had previously lost the property in an in rem tax foreclosure adjudicated by the New York Supreme Court (Kings County) in 2013.
- Riley filed suit in the U.S. District Court for the Eastern District of New York asserting claims that, if successful, would nullify the state-court foreclosure judgment and restore her ownership.
- The District Court dismissed Riley’s complaint for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine (Fed. R. Civ. P. 12(b)(1)).
- Riley appealed to the Second Circuit, which reviewed de novo whether the Rooker–Feldman doctrine barred her federal action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has jurisdiction to adjudicate Riley’s quiet-title/declaratory claims that conflict with a prior state-court foreclosure judgment | Riley sought a federal declaration that she is the free-and-clear owner and removal of six clouds on title | Defendants argued federal court lacks jurisdiction because Riley’s claims seek to overturn or nullify the state-court foreclosure judgment — Rooker–Feldman bars such relief | Rooker–Feldman applies; federal court lacked jurisdiction and dismissal was affirmed |
Key Cases Cited
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (Rooker–Feldman doctrine bars federal review of final state-court judgments)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (establishing exclusive Supreme Court appellate review of state-court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (federal appellate jurisdiction to reverse state-court judgments lies exclusively with the Supreme Court)
- Hoblock v. Albany Cty. Bd. of Elections, 422 F.3d 77 (2d Cir. 2005) (discussing Rooker–Feldman scope and standards)
- Vossbrinck v. Accredited Home Lenders, Inc., 773 F.3d 423 (2d Cir. 2014) (action seeking declaration of ownership after state foreclosure is barred by Rooker–Feldman)