Collateral Estoppel Bars Post-Foreclosure Challenges Following District Court Possession Judgments

Introduction

This commentary examines the Rhode Island Supreme Court’s order in Modupe Osifodunrin v. Marc Desjardins et al., No. 2024-100-Appeal (April 24, 2025). Ms. Osifodunrin, proceeding pro se, sought a declaratory judgment to nullify a 2011 foreclosure sale of her Hopkinton property and all subsequent transfers, including the transfer to Marc Desjardins. The Superior Court granted summary judgment to the defendants—Residential Credit Solutions, Inc. (RCS) and Mr. Desjardins—on grounds that her claims were barred by collateral estoppel, waiver, and the ten-year statute of limitations. On appeal, the Supreme Court affirmed, focusing primarily on collateral estoppel.

Key issues:

• Whether the District Court’s 2016 eviction judgment against Ms. Osifodunrin precludes relitigation of the foreclosure’s validity;
• Whether the District Court had subject-matter jurisdiction over the eviction action;
• Application of Rhode Island’s collateral estoppel doctrine to foreclosure challenges.

Parties:

• Plaintiff/Appellant: Modupe Osifodunrin (pro se)
• Defendants/Appellees: Marc Desjardins; Residential Credit Solutions, Inc. (RCS)

Summary of the Judgment

The Supreme Court, in a per curiam order, reviewed de novo the Superior Court’s grant of summary judgment to RCS and Mr. Desjardins. It held that:

1. The District Court had exclusive jurisdiction under G.L. 1956 § 8-8-3(a)(2) over DLJ Mortgage Capital, Inc.’s 2016 eviction action following the 2011 foreclosure.
2. The 2016 bench judgment ordering possession to DLJ was a final adjudication on the merits and entitled to preclusive effect.
3. Under Rhode Island’s collateral estoppel doctrine, Ms. Osifodunrin cannot relitigate the legality of RCS’s foreclosure once the District Court determined possession was proper.

Because collateral estoppel was dispositive, the Court affirmed the Superior Court’s summary judgment and returned the record.

Analysis

Precedents Cited

• RICO Corporation v. Town of Exeter, 787 A.2d 1136 (R.I. 2001): Establishes that res judicata and collateral estoppel require subject-matter jurisdiction in the prior tribunal.
• Mill Road Realty Associates, LLC v. Town of Foster, 326 A.3d 1085 (R.I. 2024): Defines subject-matter jurisdiction as the court’s authority over the nature of the case and relief sought.
• Hebden v. Antonian, 518 A.2d 1362 (R.I. 1986): Holds that a mortgagor in possession after foreclosure is a tenant at sufferance and that eviction actions against such tenants lie “clearly within” District Court jurisdiction.
• Foster-Glocester Regional School Committee v. Board of Review, 854 A.2d 1008 (R.I. 2004): Articulates the three elements of collateral estoppel in Rhode Island—identity of issues, final judgment on the merits, and identity/privity of parties.

Legal Reasoning

1. Jurisdiction of the District Court: The Court rejected Ms. Osifodunrin’s contention that the District Court lacked subject-matter jurisdiction over DLJ’s 2016 eviction action. Under § 8-8-3(a)(2), the District Court has exclusive original jurisdiction of actions “for possession of premises and estates.” As a “tenant at sufferance” after foreclosure, Ms. Osifodunrin fit squarely within this jurisdictional grant.

2. Finality and Preclusion: Having properly exercised jurisdiction, the District Court’s judgment awarding possession to DLJ in 2016 was final and on the merits. Rhode Island collateral estoppel prevents relitigation when (a) the same issue was actually litigated, (b) the prior proceeding ended in a final judgment on the merits, and (c) the party is the same or in privity.

3. Application to Foreclosure Validity: The dispositive issue—whether RCS’s foreclosure sale was valid—had been necessarily determined in the eviction action. Collateral estoppel therefore barred Ms. Osifodunrin’s new declaratory relief claims attacking the foreclosure.

Impact

This ruling cements the principle that once a lower court adjudicates possession following foreclosure, a mortgagor cannot collaterally attack the foreclosure’s validity in a subsequent declaratory-judgment action. It:

• Strengthens certainty in post-foreclosure ownership chains;
• Encourages mortgagors to assert all defenses in the eviction proceeding;
• Limits procedural vehicles—particularly pro se filings—to avoid parallel litigation;
• Guides practitioners on the importance of timely appeals and motions in eviction actions.

Complex Concepts Simplified

• Collateral Estoppel: A doctrine that prevents a party from relitigating an issue that has already been decided in an earlier lawsuit between the same parties.
• Subject-Matter Jurisdiction: The power of a court to hear and decide a particular type of case, such as eviction actions in Rhode Island’s District Court under § 8-8-3(a)(2).
• Tenant at Sufferance: A person who remains in possession of property after the expiration of a lease or after foreclosure; such a person may be evicted via an action for possession.
• Declaratory Judgment: A judicial determination of the rights of parties without ordering anything be done or awarding damages—here, Ms. Osifodunrin sought a declaration that the foreclosure was void.

Conclusion

In Modupe Osifodunrin v. Marc Desjardins, the Rhode Island Supreme Court reaffirmed that a final eviction judgment following foreclosure precludes later challenges to the foreclosure’s validity under collateral estoppel. The case underscores the importance of litigating all foreclosure-related defenses in the eviction proceeding and clarifies that District Courts have exclusive jurisdiction over post-foreclosure possession actions. By enforcing finality, the decision promotes stability in property titles and guides practitioners and pro se litigants on procedural strategy in foreclosure contexts.