On October 1, 2015, the Second Circuit issued a decision in Riley v. Commissioner of Finance, 14-4541-CV, affirming the EDNY’s dismissal of an action pursuant to the Rooker-Feldman doctrine.
In Riley, the plaintiff brought a “quiet-title action which sought a declaration of ownership of property despite a tax-foreclosure judgment already entered . . . in New York state court.” The EDNY dismissed the action pursuant to the Rooker-Feldman doctrine. The Second Circuit affirmed, explaining:
Federal appellate jurisdiction to reverse or modify a state-court judgment is lodged exclusively in the Supreme Court. 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.
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.
(Internal quotations and citations omitted).