In Bryant v. Gordon & Wong Law Group, P.C., — F.Supp.2d —-, 2010 WL 339086 (E.D.Cal. 2010), Judge England barred Plaintiff’s FDCPA claim under the Rooker-Feldman Doctrine, explaining:
The Rooker-Feldman Doctrine established the principle that federal district courts lack jurisdiction over suits that are, in substance, appeals from state court judgments. Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923); Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983). Pursuant to federal statute, final judgments or decrees rendered by the highest court of a state may only be reviewed by the United States Supreme Court. 28 U.S.C. § 1257(a); Elks Nat. Found. v. Weber, 942 F.2d 1480, 1483 (9th Cir.1991). Accordingly, the Rooker-Feldman doctrine bars federal courts from exercising subject matter jurisdiction over a proceeding in which a party losing in state court seeks what effectively would be appellate review of the state judgment in a United States district court. Doe v. Mann, 415 F.3d 1038, 1039 (9th Cir.2005) (citing Johnson v. De Grandy, 512 U.S. 997, 1005-06 (1994)). A federal district court must refuse to hear a forbidden de facto appeal from a judicial decision of a state court. Noel v. Hall, 341 F.3d 1148, 1156 (9th Cir.2003) ¶ The Supreme Court recently revisited Rooker-Feldman, clarifying the interpretation of the doctrine. In Exxon Mobile Corp. v. Saudi Basic Indus. Corp., the Supreme Court affirmed that “the Rooker-Feldman doctrine is confined to cases brought by state-court losers complaining of state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon Mobile Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). ¶ The crux of Plaintiff’s case rests on the allegation that Plaintiff was never served with Defendant’s complaint and that his bank accounts were garnished without any prior notice. However in disputing the garnishment of his accounts, Plaintiff is inherently challenging the entry of default against him and the writ of execution that authorized the garnishment. The net effect is that Plaintiff is seeking to undermine the state court judgments. These judgments were rendered before the current district court proceeding, and any action by this Court in favor of Plaintiff on his FDCPA or RFDCPA claims would necessarily require review of those state court judgments. The Rooker-Feldman doctrine specifically bars this Court from doing so. If Plaintiff believes he has been wronged by the actions of the state court, he must turn to the state for remedy. This Court lacks jurisdiction to provide redress for Plaintiff’s claims.