Edwards v. McMillen Capital, LLC, No. 18-3170 (2d Cir. 2020)
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The Second Circuit held that plaintiff did not "lose" in state court such that his federal complaint was an appeal from an adverse state-court judgment, and thus the Rooker-Feldman doctrine did not apply.
Plaintiff had filed suit against McMillen in Connecticut state court, filed two amended complaints, and then two substitute complaints. After the state court dismissed the second amended complaint and the first substitute complaint for failure to state a claim or as barred by the applicable statutes of limitations, it later dismissed the case for failure to prosecute. Plaintiff then filed this instant action in federal district court based on substantially the same facts as pleaded in the state proceedings and asserting the same claims as those in the second substitute complaint that was dismissed for failure to prosecute. Because the district court's decision was solely grounded in the Rooker-Feldman doctrine, the court vacated and remanded for further proceedings.
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