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410 F. App'x 409
2d Cir.
2011
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Background

  • Wilson, proceeding pro se, appeals a district-court dismissal of her adversary proceeding against Deutsche Bank National Trust Co. (DBNTC).
  • Foreclosure judgment favoring DBNTC was entered in Connecticut state court in June 2008.
  • Wilson filed for Chapter 7 bankruptcy and an adversary proceeding within months after the foreclosure judgment.
  • Her complaint challenged DBNTC’s standing and asserted wrongful foreclosure.
  • The district court, acting as appellate court in bankruptcy, dismissed the appeal under the Rooker-Feldman doctrine.
  • The court applies plenary review to district-court decisions in bankruptcy cases and reviews the Rooker-Feldman issue de novo.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Rooker-Feldman bars the claim Wilson contends state-court judgment is reviewable. DBNTC argues state-court judgment forecloses federal review. Yes; Rooker-Feldman applies.
Whether the state foreclosure judgment was properly connected to the bankruptcy proceeding Wilson alleges injuries from foreclosure. Foreclosure judgment relates to state proceedings; district review barred. Yes; connection warrants application of Rooker-Feldman.
Whether the stay issue affects the dismissal Open to challenge the stay violation. Rooker-Feldman dispositive, stay issue not reached. Not reviewed; not necessary to decide.

Key Cases Cited

  • In re Stoltz, 315 F.3d 80 (2d Cir. 2002) (premise that district-court rulings in bankruptcy are reviewed de novo for law and facts for factual findings are upheld unless clearly erroneous)
  • In re Enron Corp., 419 F.3d 115 (2d Cir. 2005) (bankruptcy appellate review standards; de novo for law, clear error for facts)
  • Feldman, 460 U.S. 462 (1983) (Rooker–Feldman doctrine governs federal review of state-court judgments)
  • Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (basis for Rooker–Feldman doctrine limitations)
  • Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (modification of Rooker–Feldman test; four elements)
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Case Details

Case Name: Wilson v. Deutsche Bank National Trust
Court Name: Court of Appeals for the Second Circuit
Date Published: Feb 18, 2011
Citations: 410 F. App'x 409; 10-2021-bk
Docket Number: 10-2021-bk
Court Abbreviation: 2d Cir.
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    Wilson v. Deutsche Bank National Trust, 410 F. App'x 409