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Keywords

lawsuitsettlementplaintiffdefendantjurisdictionattorneyappealcorporationclass actiondue processcommon law
plaintiffdefendantjurisdictiondamagesattorneyappealmalpracticetrustclass action

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Kamilewicz v. Bank of Boston Corp., 92 F.3d 506

Facts

The plaintiffs, including Dexter Kamilewicz, were part of a class action in Alabama against BancBoston Mortgage Corporation regarding the calculation of surplus in escrow accounts. After the Alabama court approved a settlement that resulted in minimal recovery for the class members and significant attorney fees, the plaintiffs filed a federal lawsuit alleging violations of federal law and common law claims. They contended that the settlement was unfair and that they were not adequately represented in the state action.

A class action in Alabama cost Dexter Kamilewicz $91.33 in attorney fees to recover $2.19 on the merits. When he learned of this news, he and the other plaintiffs (his wife and Martha Preston) sued the class action attorneys (as well as certain defendants in the Alabama action) in the District Court for the Northern District of Illinois.

Issue

Whether the federal district court had jurisdiction to hear the plaintiffs' claims given the Rooker–Feldman doctrine, which prohibits federal courts from reviewing state court judgments.

The Court of Appeals, Terence T. Evans, Circuit Judge, held that district court was barred, under Rooker–Feldman doctrine, from exercising jurisdiction over plaintiffs' federal action.

Rule

The Rooker–Feldman doctrine bars federal district courts from exercising jurisdiction over cases that are essentially appeals from state court judgments, even if the claims are framed as independent federal claims.

The Rooker–Feldman doctrine grows out of two Supreme Court cases: Rooker v. Fidelity Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923), and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 103 S.Ct. 1303, 75 L.Ed.2d 206 (1983).

Analysis

The court determined that the plaintiffs' federal claims were essentially a collateral attack on the state court's judgment regarding the settlement and attorney fees. Since the injuries claimed by the plaintiffs stemmed directly from the state court's approval of the settlement, the federal court lacked jurisdiction under the Rooker–Feldman doctrine. The court emphasized that it could not review the fairness of the state court's decision, regardless of the plaintiffs' arguments about personal jurisdiction and due process.

The district court concluded that the Kamilewicz plaintiffs were in the position of defendants in this aspect of the state court proceedings. That conclusion has some support in logic and bolsters a finding of a Rooker–Feldman bar.

Conclusion

The Court of Appeals affirmed the district court's dismissal of the case, concluding that the Rooker–Feldman doctrine barred the federal action.

Because we agree that Rooker–Feldman bars this action, the judgment of the district court is Affirmed.

Who won?

BancBoston Mortgage Corporation and the other defendants prevailed because the court found that the federal claims were barred by the Rooker–Feldman doctrine, which prohibits federal review of state court judgments.

The court found that even though the federal case was 'dressed up' as a claim for RICO damages or for attorney malpractice, it was, nevertheless, a collateral attack on a state court judgment which would require that he consider issues 'inextricably intertwined' with the state court case.

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