Rooker-Feldman doctrine bars man’s lawsuit alleging false statements

December 11, 2014

A man challenging a garnishment order entered in state court should have challenged the order in that court system instead of filing a federal lawsuit, the 7th Circuit Court of Appeals ruled Thursday. The judges affirmed the dismissal of his suit based on the Rooker-Feldman doctrine.

A small claims court in Marion County entered a judgment near $1,000 against Kevin Harold, which he never paid. Almost 20 years later, attorney Christopher Steel, claiming to represent the judgment creditor, asked the court to garnish Harold’s wages. Harold argued Steel misrepresented the judgment creditor’s identity and did not represent the only entity authorized to enforce the judgment. The trial court entered a garnishment order. Instead of appealing, Harold filed a federal suit under the Fair Debt Collection Practices Act, arguing Steel and his law firm violated 15 U.S.C. Section 1692e by making false statements.

Judge Tanya Walton Pratt in the U.S. District Court, Southern District of Indiana dismissed the suit for want of subject-matter jurisdiction because it is barred by the Rooker-Feldmen doctrine since it contests a state court’s decision.

“If Harold were to prevail in this suit, … federal courts could award damages every time a litigant in state court used an improper procedure or considered evidence that a federal judge does not think trustworthy,” Judge Frank Easterbrook wrote in Kevin L. Harold v. Christopher C. Steel and Peters & Steel LLC, 14-1875. “That duplication would greatly increase the already high cost of civil litigation.”

“Section 1692e does not even hint that federal courts have been authorized to monitor how debt-collection litigation is handled in state courts,” she continued. “Harold might have used Section 1692e to file a counterclaim in Indiana and could have appealed within the state system. He did neither. His federal suit was properly dismissed.”


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