Rooker-Feldman doctrine precludes man's claims against Lackawanna County judge

By Nicholas Malfitano | Jun 16, 2016

PHILADELPHIA – A per curiam decision from the U.S. Court of Appeals for the Third Circuit resulted in the Rooker-Feldman doctrine precluding a Scranton appellant’s claims under the Americans with Disabilities Act of 1990 against a Lackawanna County judge.

Judges Julio M. Fuentes, Cheryl Ann Krause and Anthony J. Scirica collectively ruled to deny the claims brought by John R. Walsh III against Lackawanna County Court of Common Pleas Judge Trish Corbett, believing “no substantial question” was presented in the appeal.

Walsh appealed the case from the U.S. District Court for the Middle District of Pennsylvania.

“Walsh filed in the District Court a motion to proceed in forma pauperis (IFP), along with a motion for an emergency injunction. Walsh sought to halt the auction and foreclosure of the sale of his home, scheduled for Dec. 5, 2015, which had been ordered by [the Honorable Trish] Corbett…as part of Walsh’s divorce proceedings,” the Third Circuit said.

In addition, Walsh asked the District Court to order Judge Corbett “to take notice of [his] rights under Title II of the Americans with Disabilities Act”, as the state court judge “had allegedly failed to take into account that he has a mental disability.”

Walsh also requested the Court “to appoint a new divorce master who will be respect [his] request for a reasonable accommodation of his disability in a new hearing.”

In response, the District Court found Walsh’s claims were barred by the Rooker-Feldman doctrine, which prevents a lower federal court from overseeing state court judgments.

“The Court noted that all four factors for applying the doctrine were met as: (1) Walsh lost in state court; (2) he complained of injuries caused by the state-court judgment; (3) that judgment was rendered before he filed his motion in the District Court; and (4) he was inviting the District Court to review and reject the state court judgment. The Court concluded that it lacked jurisdiction, that Walsh failed to state a claim upon which relief could be granted, and that Walsh’s claims were frivolous,” the Third Circuit said.

Walsh appealed the next day, per the federal appellate court.

“We agree with the District Court that Walsh’s complaint was barred by the Rooker-Feldman doctrine: (1) he complained about his loss in the state court (the order to auction his home); (2) he complained of the injuries caused by the state court order (that he would lose his home); (3) the state court order was entered before he commenced the federal proceeding; and (4) he invited the District Court to review and overturn the state court order. We will therefore affirm the District Court’s judgment,” the Third Circuit decided.

In one of his motions, Walsh requested the Third Circuit set aside the auction which took place on his home on Dec. 5, until his appeals were exhausted in the Commonwealth Court of Pennsylvania.

“He argues that Judge Corbett ignored his rights under the ADA and failed to provide him with due process in the state court proceeding. He complains that his wife’s brother made the only and winning bid, far under the appraised price,” the Third Circuit said.

However, the federal appellate court explained Walsh didn’t specify what authority it would have to “set aside the results of the auction.”

“Walsh is not asking us to compel the District Court to do anything; rather, he asks us to reverse the sale of his home, ordered by the state court,” the Third Circuit said. “Reversing Walsh’s home sale would not aid us in exercising our jurisdiction to review the District Court’s order. We thus lack the authority to do as he asks. Walsh’s motion and supplement are thus denied.”

U.S. Court of Appeals for the Third Circuit case 15-3927

U.S. District Court for the Eastern District of Pennsylvania case 3:15-cv-02313

From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at

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