SAVAGE v. SAVAGE (2021)

United States Court of Appeals, Ninth Circuit.2021-08-25No. No. 20-17297

Summary · law.co

Holding. The court affirmed the district court's dismissal for lack of subject matter jurisdiction under the Rooker-Feldman doctrine, as the claims were inextricably intertwined with prior state court decisions, and also affirmed the denial of postjudgment motions for reconsideration.

Colette Claire Savage appealed a federal district court's dismissal of her diversity action, which challenged judgments previously entered in Texas and California state courts. The Ninth Circuit affirmed the dismissal, finding that the federal court lacked subject matter jurisdiction to review the case under the Rooker-Feldman doctrine, which prevents federal courts from exercising appellate jurisdiction over state court decisions. The claims Savage raised were deemed "inextricably intertwined" with the prior state court rulings, meaning that federal review would impermissibly interfere with those state judgments.

The appellate court also upheld the district court's denial of Savage's postjudgment motions for reconsideration, concluding that she had failed to provide any valid legal or factual basis warranting relief under the applicable rules of civil procedure.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether the Rooker-Feldman doctrine bars federal jurisdiction over claims challenging state court judgments
Whether claims are inextricably intertwined with prior state court rulings
Whether the district court properly denied motions for reconsideration

Procedural posture

Colette Claire Savage appealed pro se from a district court judgment dismissing her federal diversity action challenging prior Texas and California state court judgments.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM ***

Colette Claire Savage appeals pro se from the district courts judgment in her diversity action challenging past Texas and California state court judgments. We have jurisdiction under 28 U.S.C. § 1291. We review de novo. Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034, 1040 (9th Cir. 2011) (dismissal under Federal Rule of Civil Procedure 12(b)(6)); Noel v. Hall, 341 F.3d 1148, 1154 (9th Cir. 2003) (dismissal under the Rooker-Feldman doctrine). We affirm.

The district court properly dismissed Savages action for lack of subject matter jurisdiction under the Rooker-Feldman doctrine because it was a “forbidden de facto appeal” of prior state court decisions and Savage raised claims that were “inextricably intertwined” with those state court decisions. See id. at 1163-65 (discussing the Rooker-Feldman doctrine); see also Cooper v. Ramos, 704 F.3d 772, 782 (9th Cir. 2012) (explaining that Rooker–Feldman doctrine bars “inextricably intertwined” claims where federal adjudication “would impermissibly undercut the state ruling on the same issues” (citation and internal quotation marks omitted)).

The district court did not abuse its discretion in denying Savages postjudgment motions for reconsideration because Savage failed to establish any basis for such relief. See Sch. Dist. No. 1J, Multnomah County, Or. v. ACandS, Inc., 5 F.3d 1255, 1262-63 (9th Cir. 1993) (setting forth standard of review and grounds for reconsideration under Rules 59(e) and 60(b)).

AFFIRMED.