Timothy J. Johnston v. Mortgage Electronic Registration Systems, Inc., et al.

The Rooker-Feldman doctrine prevents “the lower federal courts from exercising jurisdiction over cases brought by ‘state-court losers’ challenging ‘state court judgments rendered before the district court proceedings commenced.” Lance v. Dennis, 546 U.S. 429, 460 (2006), quoting Exxon-Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005) (“Exxon-Mobil”). The doctrine applies “where a party in effect seeks to take an appeal of an unfavorable state-court decision to a lower federal court.” In Lance v. Dennis, 546 U.S. at 466 (“Lance v. Dennis”), this Court held that “the Rooker-Feldman doctrine does not bar actions by nonparties to the earlier court action simply because, for purposes of preclusion law, they would be considered in privity with a party to the judgment.” The question presented is: Does Lance v. Dennis allow a plaintiff to avoid the Rooker-Feldman and sue in federal court by claiming it was not a party to the state court litigation, even when it argues that the state court judgment binds it and it uses the judgment to give it standing in federal court?