Victoria Laney v. Thomas Ray Slaten, Jr., 687 F. App'x 805

Victoria Laney, a homeowner in The Hammocks (a deed-restricted Florida community), was recalled from the HOA board in 2008 and lost an arbitration challenging the recall; the arbitrator awarded attorneys’ fees to the Association, and state court later enforced that award.
Laney alleged the Association and its agents publicly disclosed and misrepresented her debt (a letter read at a membership meeting and past-due amounts posted online), humiliated her, and that defendants regarded her as emotionally/mentally ill; she also alleged the Association caused her arrest.
Laney filed a federal suit raising FDUTPA and FCCPA claims (Counts II–III) and federal and Florida Fair Housing Act claims (Counts IV–V). The district court dismissed all counts with prejudice under Rule 12(b)(6) and announced Rule 11 sanctions against Laney and her counsel.
The district court relied in part on Rooker–Feldman to bar the FDUTPA and FCCPA claims as inextricably intertwined with prior state-court judgments enforcing the arbitration award; it dismissed the fair housing claims for failure to plead plausible housing-related injury or denial of reasonable accommodation/modification.
Laney appealed pro se. The attorney who represented her in district court later paid the defendants the sanctioned amount by settlement; the Hammocks defendants confirmed they no longer seek sanctions from Laney, and the Eleventh Circuit dismissed the sanctions portion of the appeal as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FDUTPA and FCCPA claims are barred by Rooker–Feldman	Laney contends federal court may hear her FDUTPA/FCCPA claims about allegedly improper collection/disclosure	State-court enforcement of arbitration is final; federal review would nullify those judgments	Rooker–Feldman applies; Counts II–III are barred and dismissed
Whether fair-housing claims (federal and Florida) were plausibly pleaded	Laney alleges defendants perceived her as mentally/emotionally impaired and discriminated against her	Defendants argue no allegation of denied housing, access, or reasonable modification; only interpersonal harm alleged	Dismissed for failure to state a plausible fair-housing claim under Twombly/Iqbal; statutes require housing-related injury
Whether district court properly considered state-court records on motion to dismiss	Laney suggests extraneous materials should not be considered	Defendants rely on state-court records central to claims and undisputed	Court may consider such documents on 12(b)(6) where central and undisputed; affirmed
Whether sanctions award remains reviewable on appeal	Laney challenges Rule 11 sanctions and fee award	Defendants and Laney’s former counsel say counsel paid the award and defendants no longer seek sanctions from Laney	Appeal on sanctions dismissed as moot because no live controversy remains

Glover v. Liggett Grp., Inc., 459 F.3d 1304 (11th Cir. 2006) (standard of review for 12(b)(6) dismissal)
Storck v. City of Coral Springs, 354 F.3d 1307 (11th Cir. 2003) (elements and scope of Rooker–Feldman)
Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009) (application of Rooker–Feldman to bar federal review)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (Rooker–Feldman confined to federal suits effectively seeking reversal of state judgments)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading must contain factual content enabling reasonable inference of liability)
Bhogaita v. Altamonte Heights Condo. Ass’n, 765 F.3d 1277 (11th Cir. 2014) (analysis of Fair Housing Act claims and standing under housing statutes)
Day v. Taylor, 400 F.3d 1272 (11th Cir. 2005) (allowing consideration of documents attached to motion to dismiss if central and undisputed)
Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009) (abuse-of-discretion standard for Rule 11 sanctions)
Christian Coal. of Fla., Inc. v. United States, 662 F.3d 1182 (11th Cir. 2011) (mootness doctrine where no live controversy remains)