Opinion
CIVIL ACTION NO. 17-2053
05-09-2017
DEBORAH WILLIAMS v. STEPHANO BROTHERS REAL ESTATE INVESTMENT ASSOC.
MEMORANDUM BEETLESTONE, J.
Plaintiff Deborah Williams brings this civil action against Stephano Brothers Real Estate Investment Associates ("Stephano Brothers") following proceedings in state court. For the following reasons, the Court will grant Williams leave to proceed in forma paupeirs and dismiss her complaint for lack of subject matter jurisdiction.
I. FACTS
It appears that Stephano Brothers was Williams's landlord. The complaint and documents attached to the complaint reflect that Stephano Brothers initiated ejectment proceedings against Williams on the basis that she failed to pay rent. Although Williams alleges that she did in fact pay her rent, Stephano Brothers was successful in evicting her.
After losing in state court, Williams filed her complaint in this court. She alleges that "[i]n each court below, despite compelling evidence to the contrary of Stephano Brothers claim, the deck has been stacked against [her]." (Compl. ¶ III.C.) She asks this Court to "reverse the decisions of the lower court," return her rent, and award her additional damages. (Id. ¶ V.)
II. STANDARD OF REVIEW
The Court grants Williams leave to proceed in forma pauperis because it appears that she is not capable of paying the fees to commence this civil action. As Williams is proceeding in forma pauperis, the Court must screen her complaint to determine whether it is frivolous, malicious, fails to state a claim, or seeks relief from an immune defendant. See 28 U.S.C. § 1915(e)(2)(B). Furthermore, "[i]f the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action." Fed. R. Civ. P. 12(h)(3). As Williams is proceeding pro se, the Court construes her allegations liberally. Higgs v. Att'y Gen., 655 F.3d 333, 339 (3d Cir. 2011).
III. DISCUSSION
Pursuant to the Rooker-Feldman doctrine, "federal district courts lack jurisdiction over suits that are essentially appeals from state-court judgments." Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159, 165 (3d Cir. 2010). Based on that principle, the Rooker-Feldman doctrine deprives a federal district court of jurisdiction over "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments." Id. at 166 (quotations omitted). Williams, who lost in state court, filed this action seeking reversal of the state courts' judgments because the state courts' rulings were allegedly incorrect. Accordingly, the Court lacks subject matter jurisdiction over this case because Williams is essentially seeking to appeal judgments entered against her in state court.
Even if the Rooker-Feldman doctrine did not apply, there is no basis for federal jurisdiction over this case. The complaint does not raise any issues of federal law and the parties are not citizens of different states. See 28 U.S.C. §§ 1331 & 1332. --------
IV. CONCLUSION
For the foregoing reasons, the Court will dismiss the complaint for lack of subject matter jurisdiction. As Williams cannot cure the jurisdictional defects in her claims, she will not be given leave to file an amended complaint. See Grayson v. Mayview State Hosp., 293 F.3d 103, 114 (3d Cir. 2002). An appropriate order follows.