Opinion
Civil Action 24-3193 (UNA)
11-21-2024
BARBARA HANNAH ROGERS, Plaintiff, v. U.S. BANK NATIONAL ASSOCIATION, et al., Defendants.
MEMORANDUM OPINION
ANA C. REYES, United States District Judge
This matter is before the Court on Plaintiff's application to proceed in forma pauperis (ECF No. 2) and her pro se Complaint (ECF No. 1). It appears that Plaintiff has an interest in real property in Effingham, South Carolina. She purports to assert a claim under 42 U.S.C. § 1983 for alleged violations of her rights under the United States Constitution. See Compl. at 3, 4. Her claims pertain to foreclosure proceedings in the Court of Common Pleas, State of South Carolina, County of Florence, culminating in a judgment of foreclosure in the mortgagee's favor and an order for the sale of the property at public auction, see generally Compl., Ex. (ECF No. 11), set for December 3, 2024, see id. at 4. Among other relief, Plaintiff demands “free and clear title” to the property. Id. at 5. In addition, Plaintiff appears to challenge the ruling of the United States District Court for the District of South Carolina, see id. at 4, dismissing Plaintiff's prior challenge to the South Carolina proceedings, see id., Ex. (ECF No. 1-1 at 32-35).
Only Barbara Hannah Rogers filed an application to proceed in forma pauperis, and only she is listed as a plaintiff in the Complaint. The Court proceeds as if she is the sole plaintiff.
This Court lacks jurisdiction to provide Plaintiff's requested relief. See Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (“Federal Courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute.”); NetworkIP, LLC v. FCC, 548 F.3d 116, 120 (D.C. Cir. 2008) (“It is axiomatic that subject matter jurisdiction may not be waived, and that courts may raise the issue sua sponte.”). As a general rule, a federal district court lacks jurisdiction to review the decisions of other courts. See, e.g., Petrovic v. United States, No. 1:19-cv-00482, 2019 WL 1746301, at *2 (D.D.C. Apr. 17, 2019); United States v. Choi, 818 F.Supp.2d 79, 85 (D.D.C. 2011) (citing Lewis v. Green, 629 F.Supp. 546, 553 (D.D.C. 1986)); Fleming v. United States, 847 F.Supp. 170, 172 (D.D.C. 1994) (applying District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983)); Rooker v. Fidelity Trust Co., 263 U.S. 413, 415, 416 (1923); see also Prentice v. U.S. Dist. Court for E. Dist. of Mich., 307 Fed.Appx. 460, 460 (D.C. Cir. 2008) (per curiam) (“[B]ecause a challenge to a state court action must proceed through that state's system of appellate review rather than through a federal district court, the district court properly determined it lacked jurisdiction to review action taken by a . . . state court.” (citations omitted)).
Here, if this Court were to entertain the Plaintiff's claims, it would necessarily need to review and overturn rulings of a South Carolina court and a sister federal district court over which it lacks jurisdiction. Thus, the Court dismisses the Complaint without prejudice for lack of subject matter jurisdiction and grants Plaintiff's application to proceed in forma pauperis. An Order is issued separately.