Arnold v. KJD Real Estate, LLC

Dist. Ct. erred in dismissing on Rooker-Feldman doctrine grounds plaintiff’s Rule 22 interpleader action that asked Dist. Ct. to determine ownership of certain stock under circumstances where state court had previously ordered plaintiff to turn over said stock to one defendant in interpleader action, while second defendant in interpleader action also claimed ownership to said stock via purchase agreement with plaintiff. Rooker-Feldman doctrine did not apply where: (1) second defendant in interpleader action was not party in prior state court action; and (2) instant interpleader action did not attack prior state court judgment, but rather sought determination with respect to priority of claims over said stock. Ct. further observed that on remand, Dist. Ct. may consider whether Wilton-Brillhart abstention doctrine applies where another pending, but stayed state court action involving instant parties has raised similar priority issue.