Civil Procedure — abstention

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U.S. Court of Appeals
For the Seventh Circuit

Civil

Civil Procedure — abstention

A lawsuit alleging that a debt collector lied in state court was properly dismissed under the Rooker-Feldman doctrine.

“The Rooker-Feldman doctrine is a matter of statutory interpretation, not of constitutional command. Congress is free to authorize federal collateral review of state civil judgments—though there may be limits to how far national law can specify procedures that state courts must use, as Judge Sykes’s concurring opinion in Suesz explains, 757 F.3d at 650–55—but 15 U.S.C. §1692e does not approach the limits of federal power. Section 1692e forbids debt collectors to tell lies but does not suggest that federal courts are to review state-court decisions about whether lies have been told. Section 1692e does not even hint that federal courts have been authorized to monitor how debt-collection litigation is handled in state courts. Section 1692i (the subject of Suesz) authorizes federal courts to address one specific aspect of state debt-collection litigation; §1692e lacks a parallel reference to the conduct of litigation in state courts, so the norm from the Rooker-Feldman doctrine controls.

Harold might have used §1692e to file a counterclaim in Indiana and could have appealed within the state system.

He did neither. His federal suit was properly dismissed.”

Affirmed.

14-1875 Harold v. Steel

Appeal from the United States District Court for the Southern District of Indiana, Pratt, J., Easterbrook, J.

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