Third Circuit cites Rooker-Feldman doctrine in barring state court judgment appeal

By Nicholas Malfitano | Mar 16, 2016

U.S. Court of Appeals for the Third Circuit  

PHILADELPHIA – One party’s attempt to appeal the dismissal of a complaint challenging judgment levied against him in a state court mortgage foreclosure action is barred by the Rooker-Feldman doctrine.

U.S. Court of Appeals for the Third Circuit judges Thomas L. Ambro, Joseph A. Greenaway Jr. and Dolores Sloviter decided such a ruling in a per curiam opinion issued Friday.

Appellant Donald Watkins Jr. was a defendant in a mortgage foreclosure lawsuit in the Philadelphia County Court of Common Pleas, who found himself faced with both a default judgment after failing to appear for proceedings and his property being subject to sheriff’s sale.

After the state court judgment was handed down, Watkins made several attempts to stop the property sale and filed for removal to the U.S. District Court for the Eastern District of Pennsylvania, claiming he had not been given proper notice or an opportunity to present evidence in the state court proceedings, and was racially discriminated against.

The District Court dismissed Watkins’s complaint because his seeking of a ruling that would override the state court judgment caused it to lack jurisdiction under the Rooker-Feldman doctrine. This doctrine states that a federal court does not have jurisdiction to review decisions of state courts or claims “inextricably intertwined” with an earlier state court judgment.

Watkins appealed the decision, claiming Rooker-Feldman did not apply in his case because “the underlying state court judgment is void and because the state court proceeding violated his constitutional rights to due process and equal protection.”

The Third Circuit framed Watkins’ case as meeting perfectly the criteria outlined by Rooker-Feldman, which are: “(1) The federal plaintiff lost in state court; (2) The plaintiff complains of injuries caused by the state court judgments; (3) Those judgments were rendered before the federal suit was filed; and (4) The plaintiff is inviting the district court to review and reject the state judgments.”

“In bringing a removal action, Watkins attempts to do exactly what Rooker-Feldman prohibits: use a lower federal court to overturn an adverse judgment from a state court,” the Third Circuit said.

The federal appeals court labeled Watkins’s argument that Rooker-Feldman does not apply due to a void state court judgment as “nothing more than a disagreement with the state court’s decision on his foreclosure action” and his constitutional arguments as no more than an attempt to gain federal review of a state court judgment.

“A party who seeks to overturn a state court judgment must proceed through the state judicial system and can seek federal review only from the United States Supreme Court. Accordingly, we will affirm the judgment of the District Court,” the Third Circuit said.

The appellee is represented by Robert W. Williams of Milstead & Associates, in Marlton, N.J.

U.S. Court of Appeals for the Third Circuit case 15-2866

U.S. District Court for the Eastern District of Pennsylvania case 2:15-cv-01981

From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at

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