Vuyanich v. Borough of Smithton, No. 20-1813 (3d Cir. 2021)
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The Borough brought misdemeanor criminal charges against the owner for abandoning inoperable vehicles, appliances, and other trash on his property, in violation of ordinances and statutes. During a status conference, the judge stated that, after the expiration of 20 days, the Borough could enter and start the clean-up; 21 days after the hearing, the Borough began cleaning the property without the owners’ permission or a warrant. Believing some of the removed items to be valuable, the owners sent a cease-and-desist letter and eventually filed suit under 42 U.S.C. 1983 with state law claims for conversion and trespass.
The district court that it lacked jurisdiction under the Rooker-Feldman doctrine, which precludes federal district courts from exercising jurisdiction over appeals from state court judgments. Meanwhile, the owner was convicted of the public nuisance charge. The Third Circuit reversed. The Rooker-Feldman doctrine is narrow and defeats federal subject-matter jurisdiction only under limited circumstances. There is a precise four-pronged inquiry. When even one of the four prongs is not satisfied, it is not proper to dismiss on Rooker-Feldman grounds. This case does not satisfy all four prongs. Any injury the owners suffered was not “caused by” a state court judgment; even if the Borough lacked independent authority to seize the property, the state court “acquiesced in” or “ratified” the Borough’s seizure of the property rather than having “produced” it. The owners did not challenge the state court judgment but brought independent constitutional claims.
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