Klein v. O’Brien

Dist. Ct. did not err in entering judgment in defendant’s favor in section 1983 action in which plaintiff-stepfather alleged that defendant-stepdaughter and executor of her mother’s estate allocated too much of settlement proceeds to herself via damages for emotional distress arising out of fatal accident involving defendant’s mother/plaintiff’s wife, and that defendant conspired with state judges and others who permitted defendant to make said allocation to herself. Dist. Ct. could properly find that if anything went wrong during state court litigation between instant parties, proper step for plaintiff was to ask rendering state court to modify its judgment to correct any error. As such, plaintiff could not seek recourse via instant section 1983 action either because of claim preclusion principals or because certain aspect of Rooker-Feldman doctrine precludes actions that characterize alleged errors committed during course of state litigation as federal constitutional torts. Plaintiff also failed to address portions of Dist. Ct.’s decision that were made in favor of defendant.