MATRIX INVESTMENT CORPORATION v. WARD, (D.Conn. 2003)

STEFAN R. UNDERHILL, District Judge

Matrix Investment Corporation ("Matrix") filed a complaint on September 17, 2003, seeking to stay and enjoin enforcement of a small claims judgment obtained by Ron Ward against Matrix. This court has reviewed the complaint to determine whether it has subject matter jurisdiction over the claim. For the reasons stated below, Matrix's complaint is dismissed, sua sponte.

The following allegations are assumed to be true for present purposes. From June 1999 until June 2001, defendant, Ward was employed with Matrix as its office manager. In June 2002, defendant filed a claim with the State of Connecticut Department of Labor (the "Department") for unpaid portions of his salary, including compensation for overtime and vacation time. The Department's investigation concluded that Ward was exempt from overtime compensation under 29 U.S.C. § 213(a). Matrix paid Ward the amount the Department determined was owed to him. Nevertheless, Ward subsequently filed a complaint in New London Small Claims Court, seeking compensation for unpaid vacation time.

Ward contended that the prior settlement accounted only for unpaid overtime. The Small Claims Court did not hear Matrix's evidence concerning Ward's exempt status, and awarded Ward a greater sum than Ward had initially requested from the Department. Matrix now seeks to have the Small Claims Court decision stayed and enjoined until the District Court can rule on the matter.

Matrix's claim must be dismissed for two reasons. First, rulings from Connecticut Small Claims Courts are not subject to appeal. Second, under the Rooker-Feldman doctrine, the federal district courts cannot hear collateral attacks on state court judgments. Such a review would amount to appellate jurisdiction, whereas federal district courts are courts of original jurisdiction only.

First, Connecticut General Statutes § 51-197a and § 52-263 both articulate the principle, in no uncertain terms, that small claims cases "shall not be appealable. . . ." Decisions rendered in Connecticut Small Claims Court are "final and conclusive on the parties." Beizer v. Dobrowolski 1994 Conn. Super. LEXIS 344, at *5-6 (1994); see also Connecticut Practice Book § 581. The Small Claims Court itself may vacate its own rulings within four months of decision. The ruling at issue in this complaint was handed down in December 2002, nine months before Matrix filed in this Court.

A writ of error is available to parties dissatisfied with the Small Claims Court's refusal to grant a motion to transfer a case to the Connecticut Superior Court. Cannavo Enterprises. Inc. v. Burns, 194 Conn. 43, 48, 478 A.2d 601, 604 (1984). A defendant's failure to move for transfer or remove to federal court amounts to consent to be subject to the small claims forum. Veterans Mem'1 Med. Ctr. v. Townsend, 49 Conn. App. 198, 200-01, 712 A.2d 993, 995 (Conn.App. 1998). Apart from these available remedies, neither of which is relevant to the present complaint, the determination of the Connecticut Small Claims Court represents the last word on matters decided there.

Second, under the Supreme Court's decisions in Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), collectively known as the Rooker-Feldman doctrine, a federal district court lacks jurisdiction to hear collateral attacks on state court judgments. Rooker-Feldman challenges may be brought by either party to the case or by the court, sua sponte. Moccio v. New York State Office of Court Admin., 95 F.3d 195, 198 (2d Cir. 1996) (citations omitted).

It is well settled that, under the Rooker-Feldman doctrine, federal district courts have no jurisdiction to hear claims that have been decided in a prior state court action. See Feldman, 460 U.S. at 482;Rooker, 263 U.S. at 416; Phifer v. City of New York, 289 F.3d 49, 52 (2d Cir. 2001). Such review serves an appellate function, exceeding the original jurisdiction reserved to the district court. Rooker, 263 U.S. at 416. Rulings handed down by a state court and issues "inextricably intertwined" with state court judgments are similarly barred from federal review. See Feldman, 460 U.S. at 486-87. The Second Circuit has defined "inextricably intertwined" to include circumstances in which hearing the claim would allow a collateral attack on the state court's ruling.Moccio, 95 F.3d at 199-200.

The New London Small Claims Court's decision cannot be challenged in this court. Plaintiff had ample opportunity to remove to federal district court, but chose to remain bound by the small claims process, including its lack of a right to appeal. Matrix cannot now attempt to launch a collateral attack on the state court judgment. The Rooker-Feldman doctrine strips federal district courts of jurisdiction to hear such a claim. Accordingly, the court hereby dismisses the complaint sua sponte on ground that this court does not possess subject matter jurisdiction to hear it.

The complaint is DISMISSED with prejudice. The clerk shall enter judgment and close the file.