Second Circuit Affirms Dismissal of Action Against Town

On May 19, 2014, the United States Court of Appeals for the Second Circuit affirmed a decision of the United States District Court for the District of Connecticut granting a motion to dismiss filed by RRD Partner Michael Ryan and Associate Jonathan Zellner on the grounds that the underlying action was barred by the Rooker-Feldman doctrine.  This doctrine—which developed from the United States Supreme Court’s decisions in Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)—prevents a United States District Court from reviewing final judgments of a state court in judicial proceedings. 

The plaintiff had lost a foreclosure action in the Connecticut Superior Court, which entered a judgment of strict foreclosure.  After title to the property was transferred to the Federal Home Loan Mortgage Corporation, a Connecticut State Marshal served the plaintiff with a notice to leave the property.  The plaintiff thereafter filed a lawsuit against the respective municipality, its police department, and its chief of police, alleging that they were being called upon to assist the State Marshal in evicting him from the property.  In the complaint, the plaintiff purported to allege violations of his Fourth, Fifth, and Fourteenth Amendment rights as well as claims for intentional infliction of emotional distress and violation of the Fair Debt Collection Practices Act.  United States District Court Judge Alfred Covello subsequently ordered dismissal of the plaintiff’s complaint on the basis that it was barred by the Rooker-Feldman doctrine.  Judge Covello found that the plaintiff’s action effectively attempted to call into question the validity of and to undo the state court’s judgment of strict foreclosure.  Following the dismissal, the plaintiff took an appeal to the Second Circuit.

On appeal, the Second Circuit likewise concluded that the plaintiff’s action was barred by the Rooker-Feldman doctrine and affirmed Judge Covello’s decision.  The Second Circuit held that the Rooker-Feldman doctrine applied because: (1) the plaintiff had lost in state court; (2) his injuries stemmed directly from the judgment of strict foreclosure; (3) the plaintiff filed his action in the district court after the state court had rendered judgment; and (4) his requested relief (an order prohibiting eviction or foreclosure) required the district court to review and reject the judgment of strict foreclosure.