Harold v. Steel

Dist. Ct. did not err in dismissing for want of prosecution plaintiff’s Fair Debt Collection Practices Act (FDCPA) action, where plaintiff alleged that defendant-debt collector violated section 1592e of FDCPA by making false statements in connection with defendant’s successful state-court action seeking to garnish plaintiff’s wages arising out of 20-year-old debt. Record showed that plaintiff did not seek review of state-court garnishment order, and Rooker-Feldman doctrine precluded plaintiff from subsequently seeking to alter state-court judgment by filing instant claim alleging that defendant made false statements during prior state-court litigation.