United States District Court, Middle District of Pennsylvania
October 2, 2014
MELISSA C. DIANA, et al., Plaintiffs,
JP MORGAN CHASE, N.A., et al., Defendants.
A. Richard Caputo United States District Judge
On October 2, 2014, a hearing was held on Plaintiffs' Request for Preliminary Injunction. At the hearing, Plaintiff noted (as did Defendants) that there was a foreclosure action pending in state court, which is what Plaintiffs seek to enjoin in this proceeding. As a result, I conclude that I do not have subject matter jurisdiction in this case because it is barred by the Rooker-Feldman Doctrine. Under the Rooker-Feldman Doctrine, federal courts lack subject matter jurisdiction when the Plaintiff complains of an injury caused by a prior state court judgment, and Plaintiff's action invites federal court review and rejection of that judgment. Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). This doctrine applies in instances such as this, where a mortgagor files suit against a mortgagee arising out of a prior judgment of foreclosure entered in state court, claiming fraud on the part of the mortgagee in an attempt to have the deed to the property restored. Gage v. Wells Fargo Bank, NA AS, 521 F.App'x 49 (3d Cir. 2013).
NOW, this 2nd day of October, 2014, IT IS HEREBY ORDERED that this case is DISMISSED for lack of subject matter jurisdiction. The Clerk of Court is instructed to mark this case as CLOSED.