Filed: Apr. 14, 2016
Latest Update: Apr. 14, 2016
Summary: 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 represent
Summary: 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 represente..
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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.
UPON DUE CONSIDERATION WHEREOF, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the District Court be and hereby is AFFIRMED.
Plaintiff-appellant Edwin Fernandez ("Fernandez"), proceeding pro se, appeals from a November 10, 2014 judgment of the District Court, which followed a November 5, 2014 order dismissing his complaint for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. Fernandez had sought compensatory and punitive damages pursuant to 42 U.S.C. § 1983 for alleged violations of his constitutional rights in connection with the enforcement of child support obligations as determined by state courts. We assume the parties' familiarity with the underlying facts, the procedural history of the case, and the issues on appeal.
We review de novo a dismissal for lack of subject-matter jurisdiction, including under Rooker-Feldman. Green v. Mattingly, 585 F.3d 97, 101 (2d Cir. 2009). The Rooker-Feldman doctrine provides that federal district courts lack subject-matter jurisdiction to review "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments." Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005).
We have identified "four `requirements' that must be met before" that doctrine is applicable. Green, 585 F.3d at 101. The District Court properly ruled that each requirement is met here.
(1) "[T]he federal-court plaintiff must have lost in state court." Id. (internal quotation marks omitted). Here, Fernandez challenges an adverse 2007 state-court judgment setting child support arrears and the 2008 denial of his petition under N.Y. C.P.L.R. Article 78, in which a state court rejected his challenge to enforcement of the arrears.
(2) "[T]he plaintiff must complain of injuries caused by [the] state-court judgment." Id. (alterations and internal quotation marks omitted). Here, Fernandez alleges injuries, such as the seizure of his cars, stemming from the 2007 and 2008 state-court judgments. Cf. Sykes v. Bank of Am., 723 F.3d 399, 403-04 (2d Cir. 2013) (finding the Rooker-Feldman doctrine inapplicable where a plaintiff did "not complain of injuries caused by a state court judgment" or "challenge the validity or enforcement of the child support order itself," but only challenged a garnishment that had not been approved by any state court).
(3) "[T]he plaintiff must invite district court review and judgment of [the state-court] judgment." Green, 585 F.3d at 101 (alterations and internal quotation marks omitted). Here, the District Court would have had to overturn the state-court judgments in order for Fernandez to prevail on his constitutional claims. He therefore sought review and rejection of those state-court judgments.
(4) "[T]he state-court judgment must have been rendered before the district court proceedings commenced." Id. (internal quotation marks omitted). Here, Fernandez filed his federal complaint in 2012, after the entry of the two state-court judgments.
Fernandez's arguments to the contrary are without merit. First, he argues that the Rooker-Feldman doctrine does not apply because no state court specifically addressed the illegal seizure of his cars. But that doctrine applies when "a federal suit complains of injury from a state-court judgment, even if it appears to complain only of a third party's actions, when the third party's actions are produced by a state-court judgment and not simply ratified, acquiesced in, or left unpunished by it." Hoblock v. Albany Cty. Bd. of Elections, 422 F.3d 77, 88 (2d Cir. 2005) (emphasis supplied). The seizure of Fernandez's cars is an injury "produced by" or caused by the state-court judgment setting arrears. See id. Second, Fernandez asserts that the doctrine does not apply because his case concerns child support, while Rooker involved a decision regarding property in a trust, and Feldman involved bar admission. See Rooker v. Fidelity Trust Co., 263 U.S. 413, 417 (1923); D.C. Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983). But the Rooker-Feldman doctrine is not limited to the exact factual situations that arose in those cases. See, e.g., Hoblock, 422 F.3d at 85-92.
CONCLUSION
We have reviewed all of the arguments raised by Fernandez on appeal and find them to be without merit. For the foregoing reasons, we AFFIRM the judgment of the District Court.
