Iqbal v. Patel

Dist. Ct. erred in dismissing plaintiff’s RICO action, alleging that defendants (operator of plaintiff’s gas station and supplier of gas for said station) acted together to defraud plaintiff out of his gas station by failing to pay for gasoline purchased on behalf of plaintiff’s gas station, where gas station was ultimately foreclosed on after plaintiff had failed to pay $65,000 judgment arising out of gasoline debt. While Dist. Ct. found that Rooker-Feldman Doctrine deprived it of jurisdiction to consider plaintiff’s claim since plaintiff was essentially seeking to overturn state-court foreclosure order, Rooker-Feldman Doctrine did not block instant lawsuit, where plaintiff sought damages for activity that he alleged predated state foreclosure action and caused injury independent of it. On remand, Dist. Ct. must make determination as to whether res judicata applied to preclude plaintiff’s RICO action to extent that RICO action was compulsory counterclaim that should have been asserted in prior debt-collection action.