518 F. App'x 498
8th Cir.2013Background
- This action originated in Minnesota state court on February 17, 2012 and was removed to federal court.
- Appellants are homeowners asserting the entities in interest in their mortgages lack authority to foreclose and sought quiet title, declaratory relief, right to accelerate, and slander of title.
- The district court denied remand and granted dismissal to Appellees; the appeal followed.
- The panel reviews de novo a dismissal for failure to state a claim, applying federal pleading standards to removed state-law claims.
- Appellants argue lack of federal jurisdiction due to a pending Minnesota eviction; this argument has been repeatedly rejected by this court.
- The court ultimately affirms the district court’s dismissal, finding the quiet-title claims fail under federal pleading standards and precedence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal jurisdiction exists | Borrowers contend ongoing Minnesota eviction yields exclusive state jurisdiction | Appellees rely on controlling precedent rejecting the exclusive jurisdiction argument | Jurisdiction affirmed; prior exclusive jurisdiction argument rejected |
| Whether the quiet title claim states a claim under federal pleading rules | Borrowers claim Minnesota §559.01 supports their quiet-title theory and merits relief | Appellees argue pleadings are nothing more than labels and conclusions under Rules 8/12(b)(6) | Dismissal affirmed under federal pleading standards |
| Whether Minnesota substantive law applies to pleading requirements | Borrowers urge Minnesota law governs the quiet-title pleading | Appellees assert federal pleading standards govern removed actions | Federal pleading standards apply to state-law claims removed to federal court |
| Whether other relief claims were properly addressed or waived | Borrowers maintain declaratory relief and slander of title should be considered | Appellees emphasize these issues are not properly raised on appeal and are waived | Waived on appeal; affirmed only as to the grounded dismissal |
Key Cases Cited
- Karnatcheva v. JPMorgan Chase Bank, N.A., 704 F.3d 545 (8th Cir. 2013) (show-me-the-note theory rejected; pleadings must state plausible claims under Rule 12(b)(6))
- Dunbar v. Wells Fargo Bank, N.A., 709 F.3d 1254 (8th Cir. 2013) (dismissal of similar quiet-title claims under Rules 8/12(b)(6))
- Iverson v. Wells Fargo Bank, N.A., 502 F. App'x 624 (8th Cir. 2013) (affirmed dismissal for lack of sufficient federal pleading with state-law claims)
- Jerde v. JPMorgan Chase Bank, N.A., 502 F. App'x 616 (8th Cir. 2013) (per curiam affirming district court on similar grounds)
- Murphy v. Aurora Loan Servs., LLC, 699 F.3d 1027 (8th Cir. 2012) (rejected similar state-law foreclosure challenges)