Independent-Injury Rule under Rooker-Feldman and Limits of Claim Preclusion: Derek Thomas v. John Bartholomew, IV

Introduction

Derek Thomas v. John Bartholomew, IV, decided April 23, 2025 by the Eleventh Circuit, addressed whether a federal court may hear claims by a pro se litigant arising from a Georgia landlord‐tenant dispute and related state‐court proceedings. Derek Thomas, the administrator of his deceased mother’s estate, occupied a rental property owned by Barnes Land & Investment Group, LLC (“BLI”). After BLI changed the locks and allegedly destroyed or removed Thomas’s property, he filed two successive state‐court actions (first in magistrate and then superior court), both of which resulted in adverse rulings and dismissal of his claims. Thomas then sued in federal court: (1) the judges and clerk who presided over and dismissed his state‐court actions (Counts 1–9); (2) the BLI defendants for federal civil‐rights conspiracies and RICO (Counts 12–14); and (3) a suite of state‐law tort and contract claims against BLI and related individuals (Counts 10–11, 15–23).

The district court dismissed all counts. On appeal, the Eleventh Circuit reviewed Rooker-Feldman, judicial and quasi-judicial immunity, claim preclusion, federal pleading standards for RICO and § 1985, and supplemental jurisdiction. It affirmed in full, clarifying that only the U.S. Supreme Court can reverse state‐court judgments under Rooker-Feldman and emphasizing that independent tort claims may proceed only if they allege injuries apart from errors in the state decisions. The court also reinforced that summary judgment and dismissals with prejudice trigger claim‐preclusion bars under Georgia law.

Summary of the Judgment

Counts 1–9 (claims against state‐court judges McLaughlin, Darden, Brewton, and clerk Castlen under 42 U.S.C. § 1983): Dismissed for lack of subject-matter jurisdiction under Rooker-Feldman; alternatively, the judges enjoy absolute judicial immunity and the clerk quasi-judicial immunity.
Counts 15–23 (state-law eviction, trespass, conversion, nuisance, emotional distress against BLI, its principals and employees): Rooker-Feldman does not apply but these claims are barred by Georgia claim preclusion—Thomas litigated identical causes of action and lost on summary judgment in superior court.
Count 12 (§ 1983 conspiracy to interfere with right to appeal): Dismissed for failure to state a claim—pro se allegations of routine lawyer‐judge communication cannot support an unlawful conspiracy.
Count 13 (federal RICO and § 1985 claim against BLI attorneys): Dismissed for failure to allege a pattern of racketeering activity—mail/wire‐fraud predicates fail as litigation filings and hearing statements are not wire fraud; § 1985 allegations are conclusory.
Count 14 (state-law fraud and civil conspiracy): Liberally construed as a state-law claim only; diversity jurisdiction lacking; dismissed when the district court declined supplemental jurisdiction.
Counts 10–11 (state-law fraud in first and second lawsuits): likewise dismissed for want of supplemental jurisdiction.

Analysis

1. Rooker-Feldman Doctrine and Judicial Immunity (Counts 1–9)

Rooker-Feldman is a jurisdictional doctrine rooted in 28 U.S.C. § 1257 and the Supreme Court’s rulings in Rooker v. Fidelity Trust Co. and District of Columbia Court of Appeals v. Feldman. It bars “state‐court losers” from using lower federal courts as appellate bodies. The Eleventh Circuit stressed four points:

Federal district courts are courts of original—not appellate—jurisdiction.
Only the U.S. Supreme Court may reverse or modify state‐court judgments.
Rooker-Feldman applies when a plaintiff complains of injury caused by a state decision and asks for its reversal.
It does not bar independent claims alleging injuries collateral to or separate from the state decision.

Thomas sought relief for alleged legal errors in the entry and denial of dispossessory warrants and appeals—an impermissible collateral attack. Alternatively, the judges’ and clerk’s acts in hearing, deciding, or signing orders were “judicial” or “quasi‐judicial,” thus protected by absolute immunity (for judges) and comparable immunity (for appellate clerks). Accordingly, the Eleventh Circuit affirmed dismissal of Counts 1–9.

2. Claim Preclusion of State-Law Torts (Counts 15–23)

Even if Rooker-Feldman does not apply, federal courts must give Georgia full faith and credit to Georgia claim‐preclusion law (O.C.G.A. § 9-12-40). Under Georgia law, a plaintiff cannot relitigate claims when:

Identity of causes of action (same subject matter or transaction).
Identity of parties or their privies.
Prior adjudication on the merits by a court of competent jurisdiction.

In the second state‐court lawsuit, Thomas asserted wrongful eviction, trespass, conversion, tortious interference, nuisance, emotional distress, unjust enrichment, privacy violations, and sought property damages arising from the same 2018 events. The superior court granted summary judgment “on the merits,” satisfying element 3. The parties overlapped (element 2) and no new independent cause of action was involved (element 1). The Eleventh Circuit thus affirmed dismissal of Counts 15–23 on claim-preclusion grounds.

3. Failure to State Federal Claims (Counts 12 & 13)

Counts 12 and 13 allege federal conspiracies (§ 1983 and § 1985) and RICO violations. Federal pleading rules (Twombly/Iqbal and Rule 9(b) for fraud) require factual specificity:

§ 1983 conspiracy (Count 12): Plaintiff must allege an agreement between a private party and a state actor to deprive constitutional rights. A single court hearing where counsel answered a judge’s question cannot support an illicit agreement. Dismissal for failure to state a claim was proper.
RICO (Count 13): A “pattern” of predicate mail or wire fraud requires at least two acts using mail or wires in furtherance of a fraudulent scheme. The Eleventh Circuit reaffirmed that mailing or emailing court filings or false statutory certifications in litigation do not constitute mail/wire fraud (Pendergraft). Thomas’s allegations failed to show a plausible scheme or actual mail/wire fraud predicating RICO. His § 1985 claim was nothing more than a formulaic allegation of unequal treatment. Both claims were correctly dismissed.

4. Supplemental Jurisdiction and State-Law Claims (Counts 10–14)

Counts 10–14, as liberally construed by the district court, raised additional state-law fraud and civil-conspiracy claims. All parties were Georgia citizens, thus diversity jurisdiction was lacking. After dismissing every federal cause of action, the district court properly declined to exercise supplemental jurisdiction (28 U.S.C. § 1367(c)(3)). The appellate court affirmed that discretion.

Impact on Future Cases

Clarification of Rooker-Feldman’s “independent‐injury rule” reaffirms that only Supreme Court review can overturn state judgments; federal courts may hear collateral tort claims only where injuries do not stem directly from alleged state‐court errors.
Reinforcement of judicial and quasi-judicial immunity underscores broad protection for state judges and clerks in performance of adjudicative duties.
Georgia claim preclusion is robust: summary‐judgment dismissals and dismissals with prejudice bar relitigation of identical causes of action, even if new labels or added defendants appear.
RICO predicate acts are narrowly construed; litigation conduct seldom qualifies as mail or wire fraud. Attorneys’ emails and courtroom statements—without evidence of a fraudulent business scheme—cannot found RICO liability.
Pro se litigants must meet the same federal pleading standards for conspiracy (§ 1983), RICO, and § 1985 claims as represented parties.

Complex Concepts Simplified

Rooker-Feldman Doctrine: A rule that federal district courts cannot review or reverse state‐court judgments—only the U.S. Supreme Court can do that. It applies when the plaintiff seeks “review and rejection” of a state decision.
Judicial Immunity: Absolute protection for judges against damages for acts within their judicial role, even if their rulings were mistaken or illegal.
Claim Preclusion (Res Judicata): Under Georgia law, if a cause of action has been finally decided on the merits by a competent court, the same parties cannot relitigate the same cause of action later—even under new labels.
Federal RICO (18 U.S.C. § 1961–1964): Civil remedy for “racketeering” requires an “enterprise” + “pattern” of predicate federal crimes (e.g., mail or wire fraud). Mere litigation allegations typically fail to satisfy the mail/wire fraud predicates.
§ 1983 Conspiracy: To hold a private actor liable under § 1983, the plaintiff must allege an agreement between the private actor and a state official to violate a constitutional right, plus an overt act in furtherance of that conspiracy.
Supplemental Jurisdiction (28 U.S.C. § 1367): Federal courts may hear related state‐law claims alongside federal claims. But if all federal claims are dismissed early, courts usually decline to keep the state claims.

Conclusion

Derek Thomas v. John Bartholomew, IV confirms the narrow scope of federal review over state adjudications, underscores strong immunity doctrines for state judges and clerks, and highlights the reach of Georgia’s claim preclusion rules. It also reiterates stringent pleading standards for conspiracy and RICO claims—even when alleged conduct arises from state litigation. For practitioners and pro se litigants, the case is a caution against collateral attacks on state judgments and a guide to structuring federal claims that genuinely extend beyond mere dissatisfaction with state‐court outcomes.