BAS, LLC v. Tommy Land

Summary

The United States District Court for the Eastern District of Arkansas granted Tommy Land’s motion to dismiss BAS, LLC’s claims arising from the tax sale of property in Greene County, Arkansas. The court held that BAS’s claims were barred by claim and issue preclusion based on prior state-court litigation concerning due process and takings claims, including the newly asserted excessive-fines claim. The claims were dismissed with prejudice.

Holdings

1. The Rooker-Feldman doctrine did not apply because BAS was not alleging injuries caused by the state-court judgments or asking the district court to review and reject those judgments; BAS was instead reasserting the same claims in a different court.
2. Claim preclusion barred BAS's claims because the prior action ended in a final judgment on the merits, the state court had jurisdiction, the action was fully contested, the two suits involved the same parties and claims, and the newly added excessive-fines claim arose from the same events and could have been brought in the first action.
3. Issue preclusion independently barred BAS from relitigating whether Land violated BAS's due-process and takings rights because those issues were identical to issues litigated and necessarily determined in the prior action by a valid and final judgment.
4. A complaint must allege sufficient facts to state a plausible claim for relief; threadbare recitals of the elements supported only by conclusory statements are insufficient.

Questions Presented

1. Whether the Rooker-Feldman doctrine barred the federal action.
2. Whether claim preclusion barred BAS's due-process, takings, Arkansas constitutional, and newly added excessive-fines claims.
3. Whether issue preclusion barred relitigation of whether Land violated BAS's constitutional rights.

Disposition

dismissed