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