Robert Watson v. Mutual fo Omaha Bank, No. 18-1978 (8th Cir. 2019)
Annotate this CaseCourt Description: Per Curiam - Before Benton, Bowman and Stras, Circuit Judges] Civil case - Mortgage law. The district court properly dismissed plaintiff's challenge to the foreclosure of his home as he was essentially asking the court to quash state court judgments; the court properly dismissed plaintiff's breach of contract claim against the title insurer as plaintiff, an incidental beneficiary of the contract, had no standing to sue.
Download PDF
United States Court of Appeals For the Eighth Circuit ___________________________ No. 18-1978 ___________________________ Robert Wayne Watson lllllllllllllllllllllPlaintiff - Appellant v. State of Nebraska lllllllllllllllllllllDefendant Mutual of Omaha Bank; Old Republic National Title Insurance Company lllllllllllllllllllllDefendants - Appellees ____________ Appeal from United States District Court for the District of Nebraska - Lincoln ____________ Submitted: January 17, 2019 Filed: January 30, 2019 [Unpublished] ____________ Before BENTON, BOWMAN, and STRAS, Circuit Judges. ____________ PER CURIAM. Robert Watson challenged the foreclosure of his home in federal court. He alleges that various state-court orders violated his equal-protection rights and, separately, that Old Republic National Title Insurance breached a title-insurance policy by failing to make an insurance payment to Mutual of Omaha Bank. The district court1 dismissed both claims. The district court lacked jurisdiction under the Rooker-Feldman doctrine to consider Watson’s equal-protection claim. See Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005) (“The Rooker-Feldman doctrine . . . [applies to] cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.”). Federal courts have no authority to “quash” state-court judgments, which is what Watson asked the district court to do. See Skit Int’l, Ltd. v. DAC Techs. of Ark., Inc., 487 F.3d 1154, 1157 (8th Cir. 2007) (describing a “classic illustration” of an appeal covered by the Rooker-Feldman doctrine). The district court also properly dismissed Watson’s breach-of-contract claim. When a state-law claim is brought in federal court, the plaintiff must meet both Article III and state standing requirements. See Myers v. Richland County, 429 F.3d 740, 749 (8th Cir. 2005). Under Nebraska law, a plaintiff like Watson may not sue for breach of contract without being either a party or an intended third-party beneficiary of the contract. See Marten v. Staab, 543 N.W.2d 436, 441–42 (Neb. 1996). We agree with the district court that Watson was, at most, an incidental beneficiary who had no standing to sue. See Palmer v. Lakeside Wellness Ctr., 798 N.W.2d 845, 850 (Neb. 2011) (discussing the requirements for enforcing a contract as a third-party beneficiary); Spring Valley IV Joint Venture v. Neb. State Bank of Omaha, 690 N.W.2d 778, 782–83 (Neb. 2005) (dismissing a 1 The Honorable Robert F. Rossiter, Jr., United States District Judge for the District of Nebraska. -2- breach-of-contract claim for lack of standing because the claimant was only an incidental beneficiary). The judgment of the district court is affirmed. See 8th Cir. R. 47B. ______________________________ -3-
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
