Judge Brian Cogan
Serial pro se litigant Anderson’s action in Manhattan Supreme Court asserted contract breach and RICO violation claims against UMG Recordings. The state court’s order dismissing suit permanently enjoined Anderson from filing further pro se actions against UMG. Purportedly invoking Federal Rule of Civil Procedure §60(b) and referring to 28 USC §1331, Anderson’s federal complaint sought the state action’s dismissal, a ruling that UMG defaulted therein, and review of the state court’s permanent injunction. Despite assuming invocation of federal question jurisdiction, District Court dismissed suit. The four factors articulated by the Second Circuit in Hoblock v. Albany County Bd of Elections were present in Anderson’s case. Thus, jurisdiction was barred by the Rooker-Feldman doctrine. Anderson lost the state action, and his claims were dismissed more than a year before his federal suit. Anderson sought to continue to press claims underlying the state action, and claimed the state court’s dismissal order injured him by preventing him from doing so. Thus, his federal case attempted to appeal a state court judgment, a “paradigmatic example” of a suit Rooker-Feldman doctrine was designed to keep out of federal court.
