E-Alert Case Updates

U.S. District Court Examines the Rooker-Feldman Doctrine and Younger Abstention Doctrine

Deborah K. Dimatteo v. Pabian Properties
No.15-833-SLR (United States District Court for the District of Delaware, November 4, 2015)
by Richard J. Medoff, Associate
Semmes, Bowen & Semmes (www.semmes.com)

Available at:
http://www.ded.uscourts.gov/sites/default/files/opinions/slr/2015/november/15-833.pdf

In Deborah K. Dimatteo v. Pabian Properties, a case involving an attempted appeal of an order from the Delaware Justice of the Peace Court, the United States District Court for the District of Delaware concluded that it lacked jurisdiction to invalidate orders of the Delaware Justice of the Peace Court under the Rooker-Feldman doctrine. Thus, Judge Sue L. Robinson dismissed the complaint for lack of jurisdiction.

By way of factual background, on November 11, 2013, Defendant Pabian Properties (“Defendant”) initiated eviction proceedings against Plaintiff Deborah K. Dimatteo (“Plaintiff”) in the Delaware Justice of the Peace Court. Plaintiff was in jail at the time and she alleged that Defendant was aware that she was in jail and did not send her a written notice of the eviction proceedings. When plaintiff was released from jail in May 2014, she contacted Defendant to determine the whereabouts of her personal belongings, and claimed that she was harassed by Defendant. Plaintiff filed a counterclaim in the Justice of the Peace Court on July 24, 2015, which was denied.

Subsequently, Plaintiff filed a lawsuit in the United States District Court for the District of Delaware, framing the action as an appeal from the Delaware Justice of the Peace Court. In the complaint, Plaintiff alleged that her rights were violated because she did not receive a written notice of eviction and sought the return of her personal belongings and costs.

The Court began its analysis by explaining that federal district courts are courts of original jurisdiction and have no authority to review final judgments of a state court in judicial proceedings. See Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923); Power v. Department of Labor, 2002 WL 976001 (D. Del. May 3, 2002).

The Court further explained that the Rooker-Feldman doctrine, espoused by the United States Supreme Court in Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983), applied in cases "brought by a state-court loser complaining of injuries caused by the 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 (2005). The Court found that Plaintiff’s claims fell under the purview of the Rooker-Feldman doctrine, as Plaintiff sought review of decisions of the Delaware Justice of the Peace Court.

According to the Court, allowing Plaintiff’s claims to proceed against Defendant would allow her to use the federal courts to appeal state court judgments and, thus, would run afoul of the Rooker-Feldman doctrine. See Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923); District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983). Thus, to the extent that Plaintiff sought to have the Court invalidate orders of the Delaware Justice of the Peace Court, the Court held that it lacked the jurisdiction to do so.

Additionally, the Court noted that it did not know the current status of the case in the Justice of the Peace Court, and that the case could be pending or on appeal. The Court concluded that to the extent that there were ongoing state judicial proceedings, the Court was required to abstain from exercising jurisdiction over Plaintiff's claims under the Younger abstention doctrine.

The Court explained that the abstention doctrine defined in Younger v. Harris, 401 U.S. 37 (1971), which provided that federal courts are not to interfere with pending state criminal proceedings, has been extended to civil cases and state administrative proceedings, and applies until all appellate remedies have been exhausted. See Middlesex County Ethics Comm'n v. Garden State Bar Ass'n, 457 U.S. 423 (1982); Huffman v. Pursue Ltd., 420 U.S. 592, 608 (1975).

The Court further explained that three (3) requirements must be met for the application of the Younger doctrine: (1) the existence of an ongoing state proceeding which is judicial in nature; (2) an ongoing state proceeding which implicates important state interests; and (3) an ongoing state proceeding which presents an adequate opportunity to raise constitutional challenges in the state proceeding. Middlesex County Ethics Comm'n, 457 U.S. at 431-432. The Court also noted that the state proceeding need not be ongoing at the time the federal complaint is before the court as long as the plaintiff had an adequate opportunity to resolve the federal issue in a state proceeding. Huffman v. Pursue Ltd., 420 U.S. at 608.

While the Court noted that it was unable to discern whether there were ongoing state judicial proceedings, the Court found that the State of Delaware had a substantial interest in the fair administration of real estate matters and that the State court proceedings provided Plaintiff with an adequate opportunity to present any potential federal claims. Accordingly, to the extent that there were ongoing proceedings, the Court concluded that it must abstain from exercising jurisdiction over Plaintiff's claims under the Younger abstention doctrine.

For the above reasons, the Court dismissed the complaint for lack of jurisdiction.