Cho v. City of New York, No. 18-337 (2d Cir. 2018)Annotate this Case
The Second Circuit vacated the district court's dismissal of plaintiff's 42 U.S.C. 1983 action, alleging that their constitutional rights were violated when they were coerced by New York City officials into signing settlement agreements waiving various constitutional rights in order to avoid eviction from their businesses and residences. The district court held that it lacked jurisdiction under the Rooker-Feldman doctrine because the settlement agreements were "so-ordered" by judges in the state-court system.
The court held that the district court's Rooker-Feldman ruling was erroneous because plaintiffs' alleged injuries were merely ratified by the state-court judgments rather than caused by them. In this case, plaintiffs were attempting to remedy an alleged injury caused when, prior to any judicial action, they were coerced to settle, not an injury that flowed from a state-court judgment. Accordingly, the court remanded to the district court for further proceedings.