In Weldon v. Asset Acceptance, LLC, 2011 WL 902018 (S.D.Ind. 2011), Judge Magnus-Stinson addressed the intersection between the Rooker-Feldman doctrine and res judicata with regard to a debt collector filing suit on a time-barred debt in state court. Judge Magnus-Stinson held that the Rooker-Feldman doctrine did not deprive the district court of jurisdiction nor did res judicata provide the debt collector with a defense to the FDCPA claim, explaining:
Defendants argue that Mr. Weldon’s FDCPA claim is barred by res judicata because the trial court was a court of competent jurisdiction, the trial court rendered a judgment on the merits, Mr. Weldon raised a statute of limitations defense in state court, and the state court action involved the same parties or their privies. ¶ Rooker-Feldman and res judicata are not co-extensive. Taylor, 374 F.3d at 535. The Court can only address res judicata if Rooker-Feldman does not apply. Id. State res judicata principles apply when the earlier action in question was decided in state court. Czarniecki v. City of Chicago, —F.3d —-, 2011 U.S.App. LEXIS 1177, *8 n. 3 (7th Cir.2011). Under Indiana law, res judicata, also known as claim pre-clusion, serves to prevent the litigation of matters that have already been litigated. TacCo Falcon Point, Inc. v. Atl. L.P. XII, 937 N.E.2d 1212, 1218 (Ind.Ct.App.2010). Claim preclusion applies when the following four factors are present: (1) the former judgment was rendered by a court of competent jurisdiction; (2) the former judgment was rendered on the merits; (3) the matter now at issue was, or could have been, determined in the prior action; and (4) the controversy adjudicated in the former action was between parties to the present suit or their privies. Id. at 1218-19. ¶ Defendants emphasize that Mr. Weldon asserted a statute of limitations defense to the trial court and argue that this proves res judicata applies. While Mr. Weldon admits that he raised the statute of limitations issue, he argues that res judicata should not apply because the trial court never addressed the merits of that argument. Both parties miss the mark on this point. Defendants’ state court debt collection action sought a judgment against Mr. Weldon for approximately $30,000 of credit card debt. Mr. Weldon’s statute of limitations defense was an affirmative defense to the merits of Defendants’ debt collection action. Reiswerg v. Statom, 926 N.E.2d 26, 33 (Ind.2010). As detailed above, how-ever, Mr. Weldon’s federal FDCPA claim is an independent claim that “has nothing to do with whether the underlying debt is valid. An FDCPA claim concerns the method of collecting the debt.” Rhines, 847 N.E.2d at 238; Spears, 745 N.E.2d at 877-78. Therefore, the key issue in this litigation is not whether the underlying debt was valid or whether the state court should have applied the statute of limitations to bar Defendants’ action, but, instead, whether Defendants violated the FDCPA by taking legal action to collect on allegedly time-barred debt. Because Mr. Weldon presents an independent federal claim that has nothing to do with the validity of the underlying debt, res judicata does not apply.