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6th Circuit: Rooker-Feldman doctrine does not apply to state court writs of garnishment
On February 26, the U.S. Court of Appeals for the Sixth Circuit reversed a district court’s decision dismissing a group of borrowers’ claims against a number of creditors and their law firms (defendants) for allegedly violating the FDCPA by charging an improper amount of post-judgment interest when trying to recover unpaid debt. According to the opinion, the consumers defaulted on their credit accounts and were sued by the defendants for unpaid debts. Judgments were awarded against the plaintiffs in Michigan state court, and the law firms representing the financial institutions obtained writs of garnishment against the plaintiffs. The plaintiffs filed a lawsuit in federal district court contending that the defendants allegedly applied an “impermissibly high interest rate” of 13 percent to the debt in violation of the FDCPA and state law. The district court dismissed the action on the grounds that it lacked subject matter jurisdiction based on the Rooker-Feldman doctrine.
On appeal, the 6th Circuit discussed the applicability of the Rooker-Feldman doctrine, which prohibits lower federal courts from reviewing state court civil judgments. The 6th Circuit concluded that the doctrine applies only when a state court renders a judgment, and not to “‘ministerial’ actions by court clerks.” In this case, the writs of garnishment were not state-court judgments that the debtors sought to have reviewed in federal court, but were rather “the result of a ‘ministerial process’. . . in which the clerk of the court has a nondiscretionary obligation to issue the writ if the request ‘appears to be correct.’” Moreover, even if the writs of garnishment were state court judgments, the plaintiffs’ alleged injuries did not stem from the writs of garnishment themselves, but rather from the post-judgment interest rate the defendants improperly included in the calculation of costs.