Rogers v. US Bank National Association
4:24-cv-04811
| D.S.C. | Jun 30, 2025Background
- Plaintiff Barbara Rogers filed a pro se action challenging the foreclosure of her Effingham, South Carolina property.
- The case was brought in federal court against U.S. Bank National Association, Select Portfolio Servicing, Inc., Caliber Home Loans, Inc., Robert E. Lee, and Chad Burgess.
- A United States Magistrate Judge recommended dismissal for lack of subject matter jurisdiction under the Rooker-Feldman doctrine.
- Plaintiff’s objections included alleged constitutional violations, improper mortgage classification, issues with chain of title, and procedural problems in state court.
- The district judge conducted a de novo review of the Report and Recommendation along with Plaintiff’s objections.
- The federal court ultimately dismissed the complaint without prejudice and without issuance or service of process.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Federal Court Jurisdiction (Rooker-Feldman) | Court has jurisdiction due to alleged federal law and constitutional violations | No jurisdiction to review or overturn state court judgments | Federal court lacks jurisdiction; Rooker-Feldman applies |
| Validity of Mortgage/Chain of Title | Broken chain of title voids mortgage, violating constitutional rights | Not directly addressed; relies on state court judgment | Claim is barred as an attempt to overturn state judgment |
| Mortgage Classification and Consumer Protection | Mortgage misclassified as installment agreement, violating consumer regulations | Not directly addressed; relies on state court judgment | Barred; inextricably intertwined with state court claims |
| Authority and Procedure in State Foreclosure | Procedural irregularities and improper authority of officers in state court proceedings | Not directly addressed; relies on state court judgment | Barred; essentially seeking appellate review of state case |
Key Cases Cited
- Mathews v. Weber, 423 U.S. 261 (The role of the magistrate judge and district court’s de novo review duty)
- D.C. Ct. of App. v. Feldman, 460 U.S. 462 (Federal court review of state court judgments is generally barred)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (Establishes Rooker-Feldman doctrine prohibiting federal appellate review of state court decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Clarifies the scope and application of the Rooker-Feldman doctrine)
- Plyler v. Moore, 129 F.3d 728 (Affirms the limited role of federal courts in reviewing state judgments)