Mains v. Citibank, N.A.

Dist. Ct. did not err in dismissing under Rooker-Feldman Doctrine series of federal actions, including actions under RESPA, RICO and FDCPA, filed by plaintiff-homeowner that essentially alleged that defendant-bank committed fraud when foreclosing on plaintiff’s home. Record showed that state court had previously granted defendant’s motion for summary judgment that was filed in foreclosure action, and thus Dist. Ct. lacked jurisdiction to consider plaintiff’s actions to extent they would overturn state-court foreclosure order if said actions were resolved in plaintiff’s favor. Ct. further found that notions of issue preclusion similarly precluded plaintiff from proceeding on his RESPA, TILA and FDCPA actions, since said claims relied on issues that were already decided in state foreclosure action. Dist. Ct. erred, though, in dismissing plaintiff’s actions with prejudice, since any dismissal pursuant to Rooker-Feldman doctrine must be without prejudice.