39 F. Supp. 3d 348
E.D.N.Y2014Background
- Winter obtained a federal money judgment in the W.D. Missouri on April 9, 2012; she later acknowledged that judgment was satisfied in that court but reserved the right to seek New York post-judgment interest.
- Winter registered the judgment in New York state court (Supreme Court, Kings County) on January 23, 2014 and filed an action there on April 18, 2014 seeking New York statutory post-judgment interest.
- Defendant removed the New York state enforcement action to this Court on May 7, 2014; Winter moved to remand for lack of subject-matter jurisdiction.
- Defendant moved to dismiss or to deem the underlying judgment satisfied; the parties fully briefed the issues and argued orally.
- Winter did not register the W.D. Missouri judgment in the Eastern District of New York under 28 U.S.C. § 1963.
- The Court concluded it lacked subject-matter jurisdiction because enforcement ancillary jurisdiction to enforce a federal judgment requires either (a) the enforcing court be the court that entered the judgment or (b) registration under § 1963.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether this Court has subject-matter jurisdiction over a state-court enforcement action of an out-of-district federal judgment removed to federal court | Winter: No — she filed in state court and did not register the federal judgment in this district, so the action could not have been brought here | Defendant: Yes — federal ancillary enforcement jurisdiction exists to enforce any federal court judgment and removal was proper; alternatively Winter could have registered in federal court | Remanded — Court lacks jurisdiction because Winter did not register the W.D. Mo. judgment under § 1963 and enforcement ancillary jurisdiction is limited to courts that entered the judgment or where the judgment is registered |
| Whether enforcement ancillary jurisdiction permits a federal court to enforce another federal court’s judgment absent registration | Winter: Ancillary jurisdiction does not extend to decrees of other federal courts without registration | Defendant: Location of issuing court is irrelevant; federal jurisdiction can reach enforcement of any federal judgment | Denied — Ancillary enforcement jurisdiction is narrow and exists to vindicate a court’s own judgments; § 1963 provides the mechanism to register and enforce out-of-district federal judgments |
| Whether Caterpillar allows removal based on a possibility plaintiff could have brought the action in federal court | Winter: Removal must be judged on how the state complaint was actually pleaded; plaintiff didn’t plead a claim that federal courts could have entertained absent registration | Defendant: Plaintiff could have registered the judgment in federal court, so removal is proper | Rejected — Court asks whether the state-court complaint as filed could originally have been brought in federal court; it could not without § 1963 registration |
| Whether the Court should dismiss or deem the judgment satisfied | Winter: Remand instead of dismissal; no jurisdiction to adjudicate satisfaction | Defendant: Move to dismiss or deem satisfied as relief | Denied — Court lacks jurisdiction to grant those remedies and remands the case to state court |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction; party asserting jurisdiction bears the burden)
- Peacock v. Thomas, 516 U.S. 349 (1996) (describes ancillary jurisdiction categories and limits enforcement ancillary jurisdiction to vindicating the court's own judgments)
- Finley v. United States, 490 U.S. 545 (1989) (ancillary jurisdiction is a narrow doctrine)
- Caterpillar Inc. v. Williams, 482 U.S. 386 (1987) (removability governed by the complaint as filed; plaintiff is master of the claim)
- Freeman v. Burlington Broadcasters, Inc., 204 F.3d 311 (2d Cir. 2000) (removal is appropriate only where the action could have been brought originally in federal court)
- Lupo v. Human Affairs Int’l, Inc., 28 F.3d 269 (2d Cir. 1994) (removal statute construed narrowly; burden on removing party)
- Epperson v. Entertainment Express, Inc., 242 F.3d 100 (2d Cir. 2001) (discusses ancillary jurisdiction and its purposes)
- Weininger v. Castro, 462 F. Supp. 2d 457 (S.D.N.Y. 2006) (registration of a foreign judgment confers ancillary jurisdiction to enforce it)
- Rubin v. Islamic Republic of Iran, 456 F. Supp. 2d 228 (D. Mass. 2006) (district court acquired jurisdiction to enforce where the judgment had been registered)
- Sephus v. Gozelski, 864 F.2d 1546 (11th Cir. 1989) (suggests registration under § 1963 alone may not always create subject-matter jurisdiction)