Commercial Litigation and Arbitration

Rooker Feldman — Circuit Split as to Whether Doctrine Applies Where State Court Judgment Was Void for Lack of Jurisdiction — Does Apply Where State Court Found (Allegedly in Error) That It Lacked Jurisdiction

Williams v. Williams, 2012 U.S. Dist. LEXIS 24846 (W.D.N.Y. Feb. 20, 2012):

Although this Court agrees with Plaintiff that these decisions make clear that his petitions were dismissed, with prejudice, on jurisdictional grounds, whether this means the Rooker-Feldman doctrine does not apply is another question. Some courts have found an exception under the doctrine where a plaintiff alleges that the state court lacked subject matter jurisdiction. See Schmitt v. Schmitt, 324 F.3d 484, 487 (7th Cir. 2003) (noting void ab initio Rooker-Feldman exception might be appropriate in bankruptcy cases, but declining to apply it for violations of constitutional jurisdictional limits); In re James, 940 F.2d 46, 52 (3d Cir. 1991). To date, the Second Circuit has not taken a position on this issue. See In re Salem, 94 Fed. Appx. 24 (2d Cir. 2004) (noting circuit split on exceptions to Rooker-Feldman doctrine where underlying state court judgment was void for lack of jurisdiction, but declining to decide issue); cf., In re Agard, 444 B.R. 231, 243 (Bankr. E.D.N.Y. 2011) (no exception for judgment procured by fraud or default judgments).

Here, however, Plaintiff is not alleging that the state court improperly rendered a judgment by ruling on a matter over which it lacked subject matter jurisdiction. Rather, Plaintiff is arguing the opposite-- that the Family Court found it had no jurisdiction, when in actuality it could have heard his petitions. Although this is a novel point, this Court is unpersuaded that it renders the Rooker-Feldman doctrine inapplicable. The Rooker-Feldman doctrine blocks district courts from exercising jurisdiction over claims that are inextricably intertwined with state court determinations. Kropelnicki v. Siegel, 290 F.3d 118, 128 (2d Cir. 2002) (quoting Feldman, 460 U.S. at 482-83 n.16). Although "where the claims were never presented in the state court proceedings and the plaintiff did not have an opportunity to present the claims in those proceedings, the claims are not 'inextricably intertwined' and therefore not barred by Rooker-Feldman," if "adjudication of a claim in federal court would require the court to determine that a state court judgment was erroneously entered or was void, the claim is inextricably intertwined with the merits of the state court judgment." Id. at 128-29. Applying the Second Circuit's four-pronged test for whether Rooker-Feldman precludes federal jurisdiction makes clear that such is the case here.

First, Plaintiff was a loser in a state court. He sought to have the Family Court resolve his claims against Ms. Williams, but had those claims dismissed with prejudice. Whether Plaintiff could bring his claims in a different state court is a matter separate from his desire to litigate in New York Family Court. In finding that it lacked jurisdiction, the Family Court disagreed with Plaintiff's contention that the issues should be addressed in that forum, and not elsewhere. Because the complaint now challenges the dismissal of the petitions by New York's Family Court as having been in violation of New York law, including the New York State Family Court Act, Plaintiff was a loser in the state court actions.

Second, Plaintiff's complaint asserts a claim on the ground that the Family Court's dismissal was in violation of New York law. He has thus alleged an injury that is caused by and the result of the state court judgment.

As to the third prong, Plaintiff did have the opportunity to present his claims as evidenced by the support magistrates clear and concise summary of them. However, Plaintiff does not appear to have litigated the merits of his substantive claims because the Family Court determined that it did not have jurisdiction. Nevertheless, by entertaining Plaintiff's claims, this Court would still find itself in a position to find the state courts' rulings erroneous. This is because, were this Court now to find the judges to have committed a constitutional violation in not exercising jurisdiction, it would, in essence, declare that the state court did have jurisdiction and it was error not to exercise that jurisdiction. "This is precisely the result that the Rooker-Feldman doctrine seeks to avoid[.]" Id. at 129. Plaintiff had the opportunity to appeal the Family Court's decisions in an effort to establish jurisdiction. He declined to do so. In filing his complaint, Plaintiff now asks this Court to act in the role of an appellate court and review the Family Court's dismissal. This it cannot do, this Court itself lacking subject matter jurisdiction. See Phifer v. City of New York, 289 F.3d 49, 57 (2d Cir. 2002) (federal court may not review family court determinations decided after plaintiff was provided "full and fair opportunity to litigate those issues"); Montesano v. New York, Nos. 05 CV 9574(GBD), 05 CV 10624(GBD), 2006 WL 944285, at *3 (S.D.N.Y. Apr. 12, 2006) (observing that a "plaintiff cannot circumvent the appropriate state appellate process by bringing a declaratory action, couched in terms of a civil rights violation, seeking federal review and vacatur of adverse state-court decisions").

Finally, in satisfaction of the fourth prong, the Family Court decisions were rendered prior to the March 21, 2011 filing date of the complaint. Having found that the Rooker-Feldman doctrine does apply in this case, this Court must conclude that it lacks subject matter jurisdiction. Plaintiff's claims against the State and Chautauqua Defendants will be dismissed.

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