Fliss v. Generation Capital I, LLC 

Dist. Ct. did not err in affirming Bankruptcy Ct.’s disallowance of defendant-creditor’s claim in plaintiff’s Chapter 13 bankruptcy proceeding as a discovery sanction. Record showed that bank had previously obtained state-court consent judgment against plaintiff and defendant, and that defendant had paid bank to take over as judgment creditor to bring instant claim in plaintiff’s Chapter 13 proceedings. Ct. of Appeals rejected defendant’s contention that Rooker-Feldman doctrine precluded plaintiff from objecting to defendant’s claim in bankruptcy court, since state-court had never previously resolved defendant’s claim under bankruptcy law. Ct. of Appeals also rejected defendant’s claim that res judicata and collateral estoppel precluded plaintiff from objecting to defendant’s claim in bankruptcy court proceeding: (1) state-court consent judgment is not entitled to collateral estoppel effect; and (2) while state court consent judgment has preclusive effect as to issues of existence of debt and amount of debt for purposes of res judicata doctrine, instant state-court consent judgment was not final for purposes of applying res judicata doctrine.