Timothy Vuyanich v. Borough of Smithton
5 F.4th 379
3rd Cir.2021Background
- Timothy and Carol Vuyanich jointly owned a residential lot filled with inoperable vehicles and debris; Borough of Smithton charged Timothy with misdemeanor public-nuisance violations and sought cleanup.
- At a June 2019 state-court status conference the judge granted Timothy 20 days to remove personal items and continued the criminal case 60 days; the order did not specify what property the Borough could permanently seize.
- On day 21 the Borough (and contractors) began seizing and removing vehicles and other items without a warrant; Vuyaniches allege trespass, conversion, and constitutional violations (Fourth, Fifth, Fourteenth Amendments) and sued under 42 U.S.C. § 1983 plus state-law claims.
- The district court dismissed the federal suit for lack of subject-matter jurisdiction under the Rooker–Feldman doctrine; the Vuyaniches appealed and Timothy was later convicted in state court.
- The Third Circuit applied the four-pronged Rooker–Feldman test and held the doctrine did not bar the federal suit because (1) the plaintiffs’ injuries were caused by defendants’ actions, not produced by the state-court judgment (Prong 2), and (2) plaintiffs did not invite the district court to review or reject the state order (Prong 4).
- The court also held Carol (a nonparty to the state proceeding) was not barred by Rooker–Feldman through privity in light of Lance v. Dennis, and it declined to resolve alternative defenses (issue preclusion, Heck) and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars federal suit because injury was caused by state-court judgment (Prong 2) | Vuyanich: state order authorized cleanup and thus caused loss of property | Defendants: Borough and contractors, not the state order, caused the injury by seizing and disposing of property | Court: Prong 2 not met — injuries traceable to defendants’ conduct, not produced by the state judgment |
| Whether federal suit asks district court to review/reject state judgment (Prong 4) | Vuyanich: federal claims necessarily challenge the state order’s validity | Defendants: plaintiffs seek to undermine the state order and thus request review/rejection | Court: Prong 4 not met — plaintiffs assert independent claims for damages and do not seek to vacate the state order |
| Whether a nonparty (Carol) is barred via privity (Prong 1/privity) | Carol: not a party to state case and may pursue federal claims | Defendants: Carol is in privity with Timothy (joint ownership) so Rooker–Feldman should bar her claims | Court: Carol not barred — Lance v. Dennis prevents automatic Rooker–Feldman bar for nonparties merely in privity |
| Whether case should be dismissed on alternative grounds (issue preclusion or Heck) | Vuyanich: claims viable in federal court; Heck inapplicable because conviction occurred after dismissal | Defendants: preclusion and Heck bar (or limit) §1983 recovery | Court: Declined to decide alternative defenses on appeal; those are nonjurisdictional and should be addressed on remand by the district court |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (establishing that federal district courts cannot review final state-court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (same; recognized appeals-from-state-court judgments are reserved to the Supreme Court)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (narrowing Rooker–Feldman and distinguishing it from preclusion doctrines)
- Great W. Mining & Min. Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir.) (articulating the four-prong Rooker–Feldman test)
- Lance v. Dennis, 546 U.S. 459 (holding Rooker–Feldman does not bar suits by nonparties merely considered in privity under preclusion law)
- Heck v. Humphrey, 512 U.S. 477 (holding §1983 damages claim accrues only after related conviction is invalidated)
- In re Philadelphia Ent. & Dev. Partners, 879 F.3d 492 (3d Cir.) (federal court may hear independent claims even if they contradict state-court conclusions)
- Malhan v. Sec’y, United States Dep’t of State, 938 F.3d 453 (3d Cir.) (discussing practical-finality approach to what constitutes a judgment)