Eleventh Circuit: Federal-Statute Pleading Triggers § 1331 Jurisdiction and Rooker–Feldman Requires Claim-by-Claim Screening (Post-Foreclosure Suits)

1. Introduction

Alice Bruce and Roy W. Bruce (the “Bruces”), proceeding pro se, sued U.S. Bank National Association and later added U.S. Bank’s foreclosure counsel (Meghan P. Keane) and her firm (Bitman O’Brien, PLLC), challenging conduct surrounding a Florida state-court foreclosure judgment entered on July 18, 2024 and a foreclosure sale on March 10, 2025.

The district court dismissed the “case” with prejudice for lack of subject-matter jurisdiction, reasoning that (i) no federal-question jurisdiction existed, (ii) diversity was inadequately pleaded, and (iii) the entire action was barred by Rooker–Feldman.

The Eleventh Circuit vacated and remanded, holding the district court (a) wrongly rejected federal-question jurisdiction given the face of the pleadings and (b) misapplied Rooker–Feldman by failing to conduct a claim-by-claim analysis and by dismissing the entire action wholesale—while also noting that jurisdictional dismissals cannot be with prejudice.

2. Summary of the Opinion

  • Federal-question jurisdiction existed because the amended pleadings asserted claims under federal statutes (including the FDCPA, and in the later pleading TILA and RESPA), which is sufficient “at least at this juncture” to invoke 28 U.S.C. § 1331.
  • The district court misapplied Rooker–Feldman by dismissing the case as a whole rather than asking whether each individual claim required review and rejection of the state-court judgment.
  • Some requested relief (e.g., declaratory relief voiding the foreclosure, quiet title, and injunctive relief blocking foreclosure) appeared to implicate Rooker–Feldman, but other claims (notably damages claims under federal statutes and claims against counsel) did not necessarily do so on their face.
  • A jurisdictional dismissal must be without prejudice; dismissing “with prejudice” on jurisdictional grounds was error.
  • The Eleventh Circuit vacated the dismissal order and remanded for the district court to determine the operative complaint (including addressing the motion to strike the second amended complaint and the motion for leave to amend) and then to apply Rooker–Feldman properly on a claim-by-claim basis, along with any other jurisdictional analysis.

3. Analysis

A. Precedents Cited

1) Federal-question jurisdiction and the well-pleaded complaint rule

  • Royal Canin U.S.A., Inc. v. Wullschleger, 604 U.S. 22 (2025): Quoted for the core proposition that § 1331 “arising under” jurisdiction is typically present “when federal law creates the cause of action asserted.” The panel used this to underscore that pleading federal statutory causes of action (FDCPA/TILA/RESPA) suffices to open the federal courthouse door even if the claims may later fail on the merits.
  • Gunn v. Minton, 568 U.S. 251 (2013): Quoted within Royal Canin for the “federal law creates the cause of action” formulation, reinforcing the straightforward path to § 1331 when a complaint seeks relief under federal statutes.
  • Schleider v. GVDB Operations, LLC, 121 F.4th 149 (11th Cir. 2024) and Caterpillar Inc. v. Williams, 482 U.S. 386 (1987): Cited for the well-pleaded complaint rule—federal jurisdiction exists only when a federal question is presented on the face of the plaintiff’s properly pleaded complaint. The panel applied this rule to the Bruces’ pleadings, emphasizing the district court’s error in looking instead to the nature of the underlying state foreclosure complaint and U.S. Bank’s foreclosure rights.

2) Rooker–Feldman doctrine and the required granularity

  • Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983): The foundational cases establishing that lower federal courts cannot function as appellate tribunals over state-court judgments.
  • Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005): Quoted for Rooker–Feldman’s narrow scope—confined to suits by state-court losers complaining of injuries caused by state-court judgments and inviting federal review and rejection of those judgments. This framed the Eleventh Circuit’s skepticism of the district court’s “one-size-fits-all” dismissal.
  • Target Media Partners v. Specialty Mktg. Corp., 881 F.3d 1279 (11th Cir. 2018): Cited for the Eleventh Circuit’s articulation that Rooker–Feldman is a subject-matter jurisdiction doctrine and bars cases that are effectively appeals from state-court decisions.
  • Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021): The pivotal Eleventh Circuit authority invoked to require a claim-by-claim analysis. The panel relied on Behr to hold that district courts must not ask whether the “whole complaint” challenges a state judgment, but whether resolution of each individual claim requires reviewing and rejecting the state-court judgment.

3) Dismissal “with prejudice” and jurisdictional limits

  • McIntosh v. Royal Caribbean Cruises, Ltd., 5 F.4th 1309 (11th Cir. 2021): Cited for the rule that if subject-matter jurisdiction does not exist, dismissal must be without prejudice.
  • Target Media Partners v. Specialty Mktg. Corp., 881 F.3d 1279 (11th Cir. 2018): Reiterated to emphasize that Rooker–Feldman is jurisdictional in nature—supporting why a “with prejudice” dismissal was improper.

4) Record supplementation (procedural aside)

  • Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021): Also cited for the de novo standard of review on subject-matter jurisdiction.
  • Est. of Keeter v. Comm'r of Internal Revenue, 75 F.4th 1268 (11th Cir. 2023): Mentioned in the discussion rejecting supplementation; the panel declined to enlarge the record, finding the proposed material irrelevant to the jurisdictional issues presented.

B. Legal Reasoning

1) The district court’s federal-question mistake

The appellate court treated the jurisdictional inquiry as a straightforward application of the well-pleaded complaint rule: if the plaintiff’s complaint (as filed in federal court) pleads a federal cause of action, § 1331 is satisfied. The Bruces pleaded federal statutory claims (FDCPA in the first amended complaint, and FDCPA plus TILA and RESPA in the second amended complaint). That pleading posture was enough to invoke federal-question jurisdiction even if the claims might later be dismissed for failure to state a claim or other defenses.

The panel further noted that once § 1331 jurisdiction exists, the district court is “empowered” to decide whether to exercise supplemental jurisdiction over state-law claims—implicitly correcting the district court’s “no federal issue” framing.

2) Rooker–Feldman requires sorting claims, not labeling the case

The Eleventh Circuit’s core corrective move was methodological: Rooker–Feldman must be applied claim by claim. The district court, relying on its earlier injunction-related order, treated the entire lawsuit as an impermissible attempt to undo the foreclosure judgment. The panel held that was the wrong question under Behr v. Campbell.

Applying the proper lens, the panel distinguished between claims that clearly sought to invalidate the state judgment (e.g., declaratory relief voiding foreclosure, quiet title, injunctions preventing foreclosure) and other claims that sought damages under federal statutes or against non-bank defendants (counsel/law firm) and “do not appear to directly seek to overturn” the state judgment. Those latter claims may still face other hurdles (preclusion, merits, pleading defects), but they are not automatically jurisdiction-barred by Rooker–Feldman simply because the dispute’s factual backdrop is a foreclosure.

3) Jurisdictional dismissals cannot be “with prejudice”

Because lack of subject-matter jurisdiction means the court lacks power to decide the merits, the Eleventh Circuit reiterated that any such dismissal must be without prejudice. This matters practically: a “with prejudice” label can wrongly suggest claim preclusion consequences flowing from a non-merits disposition.

4) Remand mechanics: operative pleading and Rule 15 issues first

The panel also emphasized orderly procedure on remand: before applying Rooker–Feldman (or other doctrines), the district court should determine which complaint is operative by addressing the motion to strike the second amended complaint and the motion for leave to amend under Rule 15(a). Only then can the court assess jurisdiction and other defenses with clarity.

C. Impact

  • Foreclosure-adjacent federal suits: The decision reinforces that post-foreclosure litigation is not categorically barred in federal court. Claims seeking damages under federal statutes (e.g., FDCPA/TILA/RESPA) may proceed past the jurisdictional threshold even if the plaintiff also seeks state-judgment-disrupting relief that is barred.
  • Rooker–Feldman discipline: By insisting on a claim-by-claim screen, the opinion discourages district courts from using Rooker–Feldman as an omnibus dismissal tool where a complaint mixes (i) impermissible de facto appeals with (ii) independent federal or tort claims.
  • Remedial tailoring: Litigants and courts alike are pushed toward remedy-specific analysis: requests to “void” a foreclosure judgment likely implicate Rooker–Feldman, while damages claims based on alleged unlawful collection conduct may not—depending on whether liability requires rejecting the state judgment.
  • Procedural clarity: The reminder that jurisdictional dismissals must be without prejudice helps prevent overbroad preclusive effects and prompts careful separation of jurisdiction, merits, and preclusion doctrines.

4. Complex Concepts Simplified

Federal-question jurisdiction (28 U.S.C. § 1331)
A federal court can hear a case if the plaintiff’s complaint (on its face) asserts a claim created by federal law—like FDCPA, TILA, or RESPA.
Well-pleaded complaint rule
Courts look to what the plaintiff affirmatively pleads as the basis for relief, not to defenses or to what happened in a prior state case. If the complaint invokes federal law as a cause of action, that typically suffices for § 1331.
Supplemental jurisdiction
If at least one federal claim is properly in federal court, the court may (often does) also hear related state-law claims in the same lawsuit.
Rooker–Feldman doctrine
Lower federal courts cannot act like appellate courts reviewing state-court judgments. If a claim’s requested relief would require the federal court to “review and reject” the state judgment, that claim is jurisdictionally barred.
Claim-by-claim analysis
A single complaint can contain some claims barred by Rooker–Feldman and other claims that are not. Courts must analyze each claim separately rather than dismissing everything because the dispute involves a prior state judgment.
Dismissal with prejudice vs. without prejudice
“With prejudice” generally means a merits-based, final resolution preventing refiling. If the court lacks jurisdiction, it cannot decide the merits, so dismissal must be “without prejudice.”

5. Conclusion

This Eleventh Circuit decision (though designated “Not for Publication”) crystallizes three practical rules for foreclosure-related federal litigation: (1) pleading federal statutory causes of action on the face of the complaint ordinarily suffices to invoke § 1331; (2) Rooker–Feldman must be applied claim by claim, not as a blanket dismissal rationale; and (3) jurisdictional dismissals must be without prejudice.

On remand, the district court must first sort the operative pleading and then separate impermissible de facto appellate claims (e.g., voiding the foreclosure judgment) from potentially independent damages claims, leaving merits defenses and preclusion questions for the proper stage of litigation.