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Smart Summary

Factual and Procedural Background

Plaintiff Barbara J. Riley, proceeding pro se, filed a quiet-title action seeking a declaration of ownership of a property in Brooklyn. This property had already been subject to a tax-foreclosure judgment entered against Riley in New York state court. The district court dismissed Riley's complaint for lack of subject-matter jurisdiction pursuant to Federal Rule of Civil Procedure 12(b)(1), applying the Rooker-Feldman doctrine. Riley appealed the dismissal to the United States Court of Appeals for the Second Circuit.

Legal Issues Presented

  1. Whether the district court properly dismissed Riley's quiet-title action for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine, given the prior state-court tax-foreclosure judgment.

Arguments of the Parties

The opinion does not contain a detailed account of the parties' legal arguments.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) Established that federal courts lack jurisdiction to review state court judgments. Used as foundational authority for the Rooker-Feldman doctrine barring federal review of state judgments.
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) Clarified limits on federal jurisdiction over state court decisions. Applied alongside Rooker to bar federal suit seeking review of state-court judgment.
Hoblock v. Albany Cty. Bd. of Elections, 422 F.3d 77 (2d Cir. 2005) Confirmed de novo review standard for dismissals under Rooker-Feldman. Guided the court’s standard of review for the district court’s dismissal.
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) Confirmed that appellate jurisdiction to reverse state court judgments lies exclusively with the U.S. Supreme Court. Supported the court’s reasoning that federal courts lack jurisdiction to overturn state-court judgments.
Vossbrinck v. Accredited Home Lenders, Inc., 773 F.3d 423 (2d Cir. 2014) Held that actions seeking to declare property ownership after state foreclosure are barred by Rooker-Feldman. Applied as controlling precedent to affirm dismissal of Riley’s claim for lack of jurisdiction.

Court's Reasoning and Analysis

The court reasoned that federal appellate jurisdiction to overturn state court judgments is vested exclusively in the U.S. Supreme Court, as established in Exxon Mobil Corp. The Rooker-Feldman doctrine bars federal district courts from exercising subject-matter jurisdiction over cases that effectively seek to review or reject state court judgments. Riley's complaint sought a declaration of ownership of property already adjudicated against her in a prior state-court tax-foreclosure proceeding. The court relied on the precedent set in Vossbrinck, which held that similar actions are barred by Rooker-Feldman. Since Riley's claims invited federal review of the state-court judgment, the district court correctly dismissed the case for lack of jurisdiction. The court also noted that Riley's other arguments did not address the doctrine's applicability and were without merit.

Holding and Implications

The judgment of the district court dismissing the complaint for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine is AFFIRMED.

The direct effect of this decision is to bar Riley from pursuing her quiet-title action in federal court because it would require reviewing and rejecting a final state-court foreclosure judgment. The court did not establish any new precedent beyond reaffirming existing Rooker-Feldman principles. No broader legal implications beyond the parties are discussed.

BARBARA J. RILEY, Plaintiff-Appellant, v. COMMISSIONER OF FINANCE OF THE CITY OF NEW YORK, CITY OF NEW YORK, KELVIN MYERS, NEIGHBORHOOD RESTORE HOUSING DEVELOPMENT FUND CORP., BX REALTY CORP. 1, JAY S. MARKOWITZ, Defendants-Appellees.

FOR THE COURT: CATHERINE O'HAGAN WOLFE, Clerk of Court

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT'S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION "SUMMARY ORDER"). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 1 day of October, two thousand fifteen. PRESENT: JOHN M. WALKER, JR., REENA RAGGI, Circuit Judges, KIYO A. MATSUMOTO, District Judge. FOR APPELLANT: Barbara J. Riley, pro se, Jacksonville, Florida. FOR APPELLEES: Janet L. Zaleon, Assistant Corporation Counsel, for Zachary W. Carter, Corporation Counsel of the City of New York, New York, New York, for City of New York and Commissioner of Finance of the City of New York. Alex S. Avitabile, Esq., New York, New York, for Neighborhood Restore Housing Development Fund Corp.

The Honorable Kiyo A. Matsumoto, of the United States District Court for the Eastern District of New York, sitting by designation. --------

Appeal from a judgment of the United States District Court for the Eastern District of New York (Brian M. Cogan, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment entered on October 29, 2014, is AFFIRMED.

Plaintiff Barbara J. Riley, proceeding pro se, appeals from the dismissal of her complaint pursuant to Fed. R. Civ. P. 12(b)(1) for lack of subject-matter jurisdiction. See Decision and Order, Riley v. City of New York, No. 14 Civ. 4482 (BMC) (E.D.N.Y. Oct. 29, 2014), ECF No. 48. The district court dismissed Riley's quiet-title action—which sought a declaration of ownership of property despite a tax-foreclosure judgment already entered against Riley in New York state court—pursuant to the Rooker-Feldman doctrine. See District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983); Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923). We review de novo a district court's dismissal for lack of subject-matter jurisdiction, including a Rooker-Feldman dismissal. See Hoblock v. Albany Cty. Bd. of Elections, 422 F.3d 77, 83 (2d Cir. 2005). We assume the parties' familiarity with the facts and the record of prior proceedings, which we reference only as necessary to explain our decision to affirm.

Federal "appellate jurisdiction to reverse or modify a state-court judgment is lodged . . . exclusively in [the Supreme] Court." Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 283 (2005). On that principle, the Rooker-Feldman doctrine bars a party who has already had a judgment entered against her in state court from initiating a federal action complaining of injuries caused by the state-court judgment and inviting federal review and rejection of that judgment. See Hoblock v. Albany Cty. Bd. of Elections, 422 F.3d at 85.

The district court here correctly dismissed Riley's action pursuant to Rooker-Feldman. The complaint sought to remove six alleged clouds on Riley's claimed title to a Brooklyn property, as well as a declaratory judgment of free-and-clear ownership. Riley's claimed ownership of the property, however, was already fully adjudicated and rejected in the prior state-court proceedings. See In Rem Tax Foreclosure Action No. 51, Borough of Brooklyn, Index No. 8700/07 (N.Y. Sup. Ct. Feb. 26, 2013). In Vossbrinck v. Accredited Home Lenders, Inc., 773 F.3d 423 (2d Cir. 2014), this court held that an action seeking a declaration of property ownership after loss of title pursuant to a state-court foreclosure judgment was barred by Rooker-Feldman. See id. at 426-28. As in Vossbrinck, the district court in this case lacked subject-matter jurisdiction to review and reject the state-court foreclosure judgment and, therefore, correctly dismissed the action.

We have considered Riley's remaining arguments (none of which addresses the applicability of the Rooker-Feldman doctrine), and we conclude that they are without merit. Accordingly, the district court's judgment of dismissal is AFFIRMED.

FOR THE COURT:


CATHERINE O'HAGAN WOLFE, Clerk of Court


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Riley v. Comm'r of Fin. of N.Y., City of N.Y., Kelvin Myers, Neighborhood Restore Hous. Dev. Fund Corp.
(Oct 1, 2015)