Caldwell v. DeWoskin, ___F.3d___, case number 15-1962 (8th Cir. Aug. 5, 2016) and Flanders v. Lawrence (In re Flanders)
Caldwell v. DeWoskin, ___F.3d___, case number 15-1962 (8th Cir. Aug. 5, 2016) and Flanders v. Lawrence (In re Flanders), ___F.3d ___, case number 15-1327 (10th Cir. Aug. 5, 2016): These 2 Circuit Court decisions, one by the 8th Circuit Court of Appeals, and one by the 10th Circuit Court of Appeals, both discuss and apply the Rooker-Feldman US Supreme Court doctrine. The US Supreme Court Rooker-Feldman doctrine, named after the US Supreme Court Rooker case, and the US Supreme Court Feldman case, holds that lower federal courts (includes US bankruptcy Courts, US District Courts, BAPs, US Circuit Courts)-in fact that any US Court except for the US Supreme Court-lacks subject matter jurisdiction to hear an appeal of a state court judgment, made by a state court that had jurisdiction to issue the state court judgment.
In Caldwell (the Eighth Circuit case), a man filed bankruptcy in the midst of a matrimonial dispute. Because he refused to pay spousal maintenance after bankruptcy, the wife’s lawyer dragged him into state court. The state court jailed him for contempt until he paid overdue maintenance, ruling in the process that the automatic stay did not bar proceedings to compel payment of support. After his chapter 13 case was dismissed, the former husband sued his former wife and her lawyer in bankruptcy court for violating the automatic stay. The bankruptcy court dismissed the suit, believing there was no subject matter jurisdiction as a consequence of Rooker-Feldman. The Eighth Circuit Court of Appeals reversed, explaining that Rooker-Feldman applies when someone seeks relief from a state court judgment. The doctrine does not apply to an action seeking “relief from the allegedly illegal act or omission of an adverse party.”Because the husband was not seeking to overturn the state court decision, Rooker-Feldman did not apply. Eighth Circuit, in Caldwell, did not say whether rules of issue or claim preclusion would still result in dismissal or summary judgment after remand.
In Flanders, the Tenth Circuit, however, explored the relationship in depth between Rooker-Feldman and claim preclusion in a non-precedential opinion, and explained why res judicata or issue preclusion would still result in dismissal even if Rooker-Feldman did not apply.