Rooker-Feldman Bars Damages Claims That Functionally Undo State-Court Fee/Lien Judgments; Jurisdictional Dismissals Must Be Without Prejudice

Case: Robert Jones v. The Lamar Company, LLC, et al.
Court: United States Court of Appeals for the Eleventh Circuit
Date: March 2, 2026 (Not for publication)
Disposition: Affirmed in part; vacated and remanded with instructions in part.

1. Introduction

This appeal arises from a pro se plaintiff’s attempt to relitigate, in federal court, the financial consequences of adverse rulings in Florida state-court proceedings. Robert Jones alleged that The Lamar Company, LLC and related entities (“Lamar”) committed fraud in prior state litigation concerning an eviction dispute tied to a billboard on Jones’s property. In Jones’s telling, Lamar obtained an attorney’s-fee award through false filings and deception, then recorded liens and recovered at least $17,000 from the sale proceeds of his property.

The federal complaint asserted (i) a claim under Florida’s fraudulent lien statute, Fla. Stat. § 817.535, seeking to recoup the attorney’s fees allegedly paid due to the liens (Count One); (ii) additional counts identifying alleged “fraudulent instruments” and seeking statutory damages (Counts Two through Six); and (iii) tort-based claims tied to litigation conduct (intentional infliction of emotional distress and damages theories) (Counts Seven through Nine).

The central issues on appeal were: (1) whether Count One was barred by the Rooker-Feldman doctrine (and thus outside federal subject-matter jurisdiction), and (2) whether the district court abused its discretion by denying further leave to amend.

2. Summary of the Opinion

The Eleventh Circuit held that Count One was jurisdictionally barred by the Rooker-Feldman doctrine because Jones’s claimed injury—being forced to pay attorney’s fees via liens—was caused by the state-court judgment granting fees, and his requested relief (money to recoup what the state order compelled him to pay) would require the federal court to effectively review and reject that judgment.

The panel further held that Jones abandoned any meaningful appellate challenge to the dismissal of Counts Two through Nine by only making a passing reference to error, warranting affirmance of their dismissal with prejudice.

Finally, while agreeing that Count One must be dismissed for lack of jurisdiction, the court corrected the form of the judgment: a jurisdictional dismissal is not on the merits and must be without prejudice. It therefore vacated the dismissal as to Count One and remanded with instructions to dismiss Count One without prejudice.

3. Analysis

3.1 Precedents Cited

Foundational Rooker-Feldman authorities

  • Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983): These cases supply the doctrine’s core premise—federal district courts do not sit as appellate tribunals over state-court judgments.
  • Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005): The modern narrowing construction. The opinion uses Exxon Mobil Corp. to frame the doctrine as limited to suits by state-court losers complaining of injuries “caused by” state judgments and seeking federal “review and rejection” of those judgments.

Eleventh Circuit refinements: “narrow ground,” claim-by-claim, and injury-source inquiry

  • Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021): The court relies heavily on Behr for (i) the doctrine’s “narrow ground,” (ii) the claim-by-claim approach (“whether resolution of each individual claim requires review and rejection of a state court judgment”), and (iii) the distinction between independent damages claims versus de facto appeals.
  • May v. Morgan Cnty. Ga., 878 F.3d 1001 (11th Cir. 2017): Cited for the formulation that a barred claim is one that “at its heart challenge[s] the state court decision itself.”
  • Efron v. Candelario, 110 F.4th 1229 (11th Cir. 2024), cert. denied, 145 S. Ct. 1958 (2025): The decisive comparator. The panel uses Efron to reject “damages-only” labeling where the damages are inseparable from the state judgment’s operative effect (e.g., seeking return of money the state court ordered paid and asking for findings that the state decision was “wrongful” or “corruptly procured”).

Non-recognition of proposed Rooker-Feldman exceptions

  • Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009): Invoked to confirm that the Eleventh Circuit has not adopted an exception allowing federal review where the state judgment is allegedly void ab initio for lack of jurisdiction.
  • Efron v. Candelario, 110 F.4th at 1232 n.2: Cited for the Eleventh Circuit’s refusal to recognize an “extrinsic fraud” exception to Rooker-Feldman.

Form of dismissal for lack of jurisdiction

  • Fed. R. Civ. P. 12(h)(3): Requires dismissal whenever subject-matter jurisdiction is lacking.
  • Stalley ex rel. U.S. v. Orlando Reg'l Healthcare Sys., Inc., 524 F.3d 1229 (11th Cir. 2008): Establishes that jurisdictional dismissals are not on the merits and must be without prejudice.
  • DiMaio v. Democratic Nat'l Comm., 520 F.3d 1299 (11th Cir. 2008), and Boudloche v. Conoco Oil Corp., 615 F.2d 687 (5th Cir. 1980): Support the appellate remedy of vacating and remanding where a jurisdictional dismissal was incorrectly entered with prejudice.
  • Bonner v. City of Prichard, 661 F.2 d 12 06 (11th Cir. 1981) (en banc): Cited to confirm pre-October 1, 1981 Fifth Circuit decisions (such as Boudloche) are binding in the Eleventh Circuit.

Appellate abandonment and pro se briefing rules

  • Jacob v. Mentor Worldwide, LLC, 40 F.4th 1329 (11th Cir. 2022), and Albra v. Advan, Inc., 490 F.3d 826 (11th Cir. 2007): Pro se pleadings are liberally construed, but pro se litigants must still follow procedural rules.
  • Timson v. Sampson, 518 F.3d 870 (11th Cir. 2008), and Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014): Issues not plainly and prominently raised (or raised only perfunctorily) are deemed abandoned—even for pro se appellants.

Leave to amend and futility

  • Pinnacle Advert. & Mktg. Grp., Inc. v. Pinnacle Advert. & Mktg. Grp., LLC, 7 F.4th 989 (11th Cir. 2021), L.S. ex rel. Hernandez v. Peterson, 982 F.3d 1323 (11th Cir. 2020), and Peer v. Lewis, 606 F.3d 1306 (11th Cir. 2010): Provide the abuse-of-discretion standard for denying leave to amend, and de novo review for futility; and define abuse of discretion.
  • Woldeab v. Dekalb Cnty. Bd. of Educ., 885 F.3d 1289 (11th Cir. 2018), and Silberman v. Miami Dade Transit, 927 F.3d 1123 (11th Cir. 2019): Emphasize at least one meaningful chance to amend for pro se plaintiffs before dismissal with prejudice, while recognizing futility as a limit.
  • Foman v. Davis, 371 U.S. 178 (1962), and Hall v. United Ins. Co. of Am., 367 F.3d 1255 (11th Cir. 2004): Identify recognized reasons to deny leave (including futility) and define futility as the amended complaint still being dismissible.

Other procedural authorities

  • Cisneros v. Petland, Inc., 972 F.3d 1204 (11th Cir. 2020): The court may affirm on any ground supported by the record.
  • Caterpillar Fin. Servs. Corp. v. Venequip Mach. Sales Corp., 147 F.4th 1341 (11th Cir. 2025): Provides the Rule 12(b)(6) standard of review.
  • Lozman v. City of Riviera Beach, 713 F.3d 1066 (11th Cir. 2013): Supports judicial notice of state-court records on a motion to dismiss without converting to summary judgment.

3.2 Legal Reasoning

(a) Why Count One triggered Rooker-Feldman

The panel treated Count One as a paradigmatic “de facto appeal.” Although framed as a Florida statutory claim about fraudulent liens (Fla. Stat. § 817.535), Jones’s asserted injury and requested remedy were tethered to the state-court attorney’s-fee award and its enforcement:

  • Injury source: Jones claimed he was “wrongfully required to pay attorney's fees” and that liens were placed “to recover its attorney's fees.” The federal injury, as pleaded, materialized because the state court granted fees and allowed enforcement against the property.
  • Relief requested: Jones sought monetary damages “to recoup the attorney's fees he paid” from the property’s sale proceeds “pursuant to the state court order.”
  • Necessary federal decision: To award those damages, the district court would necessarily have to decide that the state-court fee award was wrongly entered (because procured by fraud) and thus should not have produced enforceable liens—i.e., “review and rejection” of the state judgment.

This tracks Efron v. Candelario: even when plaintiffs label their claims as fraud or constitutional violations and ask for damages, the suit is barred if there is “no distinguishing between” the damages sought and the state court’s disposition, such that the federal remedy would nullify the judgment’s practical effects.

(b) Rejection of Jones’s attempted distinctions

  • “Not a loser” in state court: The panel focused on functional effect, not labels. If the federal court must undo the state fee judgment’s operative consequences, Rooker-Feldman applies.
  • Injury “caused by Lamar,” not the judgment: The court reasoned that, as pleaded, the enforcement harm (liens and compelled payment) flowed from the state-court fee award. Under Behr v. Campbell and Efron v. Candelario, the key question is whether the “source of the plaintiff’s injury is the state-court judgment itself.”
  • Federal fraud claim “different” from the state eviction case: Differences in theory or styling do not matter if the federal claim “at its heart” challenges the state decision (May v. Morgan Cnty. Ga.) and seeks to negate its effects (Exxon Mobil Corp. v. Saudi Basic Indus. Corp.).
  • Void-for-lack-of-jurisdiction exception: The Eleventh Circuit reiterated it has “never adopted” such an exception (Casale v. Tillman) and likewise has not recognized an extrinsic fraud exception (Efron v. Candelario, 110 F.4th at 1232 n.2).

(c) Counts Two through Nine: affirmed largely on abandonment

The district court dismissed Counts Two through Nine for failure to state a claim. On appeal, Jones did not meaningfully brief those dismissals, making only a passing statement. Applying Sapuppo v. Allstate Floridian Ins. Co. and Timson v. Sampson, the panel deemed the issues abandoned and affirmed the with-prejudice dismissals.

(d) Leave to amend: futility as the backstop

Even with pro se leniency (Woldeab v. Dekalb Cnty. Bd. of Educ.; Silberman v. Miami Dade Transit), the panel agreed further amendment would be futile (Foman v. Davis; Hall v. United Ins. Co. of Am.; L.S. ex rel. Hernandez v. Peterson). The court reasoned that:

  • Any attempt to plead around Count One’s injury would still run into Rooker-Feldman so long as Jones sought to recoup fees paid because of the state fee award.
  • The remaining claims suffered from substantive defects (e.g., implausibility of IIED based on litigation conduct; and pleading “damages” as standalone causes of action), making amendment non-curative.

(e) The remedial correction: dismissal without prejudice for lack of jurisdiction

The opinion’s concrete procedural holding is that the district court’s Rooker-Feldman dismissal of Count One needed to be expressly without prejudice. Under Stalley ex rel. U.S. v. Orlando Reg'l Healthcare Sys., Inc. and DiMaio v. Democratic Nat'l Comm., jurisdictional dismissals do not reach the merits; the appropriate disposition is to vacate and remand with instructions to dismiss without prejudice.

3.3 Impact

Practical boundary for “fraudulent lien” and “fraud-on-the-court” repackaging

This decision reinforces a recurring Eleventh Circuit line: plaintiffs cannot evade Rooker-Feldman by recasting a challenge to a state-court money judgment (or its enforcement mechanisms, such as liens) as an independent fraud, due process, or statutory-liability claim when the requested federal remedy would effectively unwind the state judgment.

Strategic implications for litigants

  • State-court remedies must be pursued in state court: Allegations that a state fee award was procured by deception typically must be addressed through state appellate review or state procedures for relief from judgment—not a federal damages action designed to restore amounts paid under the judgment.
  • Pleading damages is not enough: The opinion underscores that “damages-only” framing does not save a claim if damages are inseparable from the judgment’s effect (as in Efron v. Candelario).
  • Appellate briefing discipline matters (even pro se): By affirming dismissal of Counts Two through Nine on abandonment grounds, the decision highlights that failure to develop arguments with clarity can be outcome-determinative.
  • Jurisdictional dismissals preserve refiling in a proper forum: The remand to dismiss Count One without prejudice matters because it prevents accidental merits preclusion from an erroneously “with prejudice” jurisdictional dismissal.

4. Complex Concepts Simplified

  • Subject-matter jurisdiction: The court’s authority to hear a type of case. If it’s missing, the case must be dismissed regardless of the claim’s perceived strength.
  • Rooker-Feldman doctrine: A rule preventing federal district courts from acting like appellate courts over state-court judgments. If you are effectively asking a federal trial court to undo a state judgment, Rooker-Feldman bars the suit.
  • “Injury caused by the judgment itself”: The key test. If the harm you complain about exists because the state court ordered something (e.g., you had to pay fees, and liens followed), then the injury is judgment-caused.
  • “Without prejudice” vs. “with prejudice”: “Without prejudice” means the dismissal is not a decision on the merits and does not (by itself) bar refiling in a court that has jurisdiction. Jurisdictional dismissals must be without prejudice.
  • Abandonment on appeal: If an appellant does not clearly argue an issue in the opening brief—beyond passing references—the appellate court treats it as forfeited.
  • Futility of amendment: Courts need not allow an amended complaint if the new version would still be dismissed (for jurisdictional or substantive reasons).

5. Conclusion

The Eleventh Circuit’s decision supplies two durable lessons. First, a federal claim seeking reimbursement of sums paid because of a state-court attorney’s-fee judgment—and premised on allegations that the judgment was fraudulently procured—will be treated as a forbidden de facto appeal under Rooker-Feldman where success requires the federal court to reject the state judgment’s validity or effects. Second, when dismissal is jurisdictional, it must be without prejudice, prompting vacatur and remand if the district court mistakenly dismisses with prejudice.

Result: dismissal of Counts Two through Nine with prejudice affirmed; Count One vacated and remanded for dismissal without prejudice for lack of subject-matter jurisdiction.