See Dkt. No. 17 at 6-9; Dkt. No. 22 at 7-8; and Dkt. No. 23 at 7-8. SLS also contends that Coleman's situation is indistinguishable from that of plaintiff in Mains v. Citibank, N.A., 852 F.3d 669, 676 (7th Cir. 2017), in which case the Seventh Circuit held that because plaintiff's request for relief could not be sustained without disregarding or effectively vacating the state court's foreclosure judgment, which would be incompatible with the Rooker-Feldman doctrine, dismissal was required. Dkt. No. 27 at 2.
"The Rooker-Feldman doctrine prevents lower federal courts from exercising jurisdiction over cases brought by state-court losers challenging state-court judgments rendered before the district court proceedings commenced." Mains v. Citibank, N.A., 852 F.3d 669, 675 (7th Cir. 2017). That is because "no matter how wrong a state court judgment may be under federal law, only the Supreme Court of the United States has jurisdiction to review it."
First, there is no fraud exception to Rooker-Feldman. See Bond v. Perley, 705 F. App'x 464, 465 (7th Cir. 2017), reh'g denied (Jan. 22, 2018) (citing Iqbal v. Patel, 780 F.3d 728, 729 (7th Cir. 2015)); Podemski v. U.S. Bank Nat'l Ass'n, 714 F. App'x 580, 581-82 (7th Cir. 2017) (first citing Mains v. Citibank, N.A., 852 F.3d 669, 676 (7th Cir. 2017); then citing Kelley v. Med-1 Solutions, LLC, 548 F.3d 600, 605 (7th Cir. 2008)). That doctrine is about federal judicial power, not "why a state court's judgment might be mistaken . . ."
"The Rooker-Feldman doctrine prevents lower federal courts from exercising jurisdiction over cases brought by state-court losers challenging state-court judgments rendered before the district court proceedings commenced." Mains v. Citibank, N.A. , 852 F.3d 669, 675 (7th Cir. 2017). "It ensures that lower federal courts do not exercise appellate authority over state courts."
This includes "[c]laims that directly seek to set aside a state-court judgment," and those that seek "relief that is tantamount to vacating the state judgment." Mains v. Citibank, N.A., 852 F.3d 669, 675 (7th Cir. 2017).
In her opening brief to this court, Podemski rehashes her TILA claim without confronting the district court's explanation for dismissing her suit. Yet our recent decision in Mains v. Citibank, N.A., 852 F.3d 669 (7th Cir. 2017), shows that Podemski's appeal is meritless. Like Podemski, the plaintiff in Mains sued in federal court and, relying on TILA, claimed he was entitled to keep his house because, after an Indiana court had entered a judgment foreclosing his mortgage, he told the holder of the defaulted note he was rescinding it. Mains, 852 F.3d at 674. We concluded that under Indiana law a foreclosure judgment is final, and that the plaintiff's purported rescission could not be sustained without "disregarding or effectively vacating" the state court's foreclosure judgment—an outcome incompatible with the Rooker-Feldman doctrine.
“The Rooker-Feldman doctrine prevents lower federal courts from exercising jurisdiction over cases brought by state-court losers challenging state-court judgments rendered before the district court proceedings commenced.” Mains v. Citibank, N.A., 852 F.3d 669, 675 (7th Cir. 2017); see also Brown v. Bowman, 668 F.3d 437, 442 (7th Cir. 2012).
"Claims that directly seek to set aside a state-court judgment are de facto appeals that trigger the doctrine[,] [b]ut even federal claims that were not raised in state court, or that do not on their face require review of a state court's decision, may be subject to Rooker-Feldman if those claims are closely enough related to a state-court judgment." Mains v. Citibank, N.A. , 852 F.3d 669, 675 (7th Cir. 2017) (citation omitted). The question is "whether the federal plaintiff is alleging that his injury was caused by the state-court judgment."
The Rooker-Feldman doctrine prevents a lower federal court from exercising jurisdiction over cases that challenge the outcome of a state court proceeding. See Mains v. Citibank, N.A., 852 F.3d 669, 675 (7th Cir. 2017) (citing Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005)). Federal courts lack jurisdiction over such claims because "the Supreme Court of the United States is the only federal court that may review judgments entered by state courts in civil litigation."
Id. "But if the suit does not seek to vacate the judgment of the state court and instead seeks damages for independently unlawful conduct, it is not barred by Rooker-Feldman." Mains v. Citibank, N.A., 852 F.3d 669, 675 (7th Cir. 2017). "The paradigmatic Rooker-Feldman litigant is one who . . . loses in state court and asks a federal district court to modify the state decision."