Tiffany Oliver v. Symphony Property Management LLC, et al.

Summary

The United States District Court for the Western District of Pennsylvania dismissed as moot the plaintiff’s petition for removal and change of venue and motion for enjoinder because the case had been transferred from the District of North Dakota. The court dismissed the plaintiff’s motion seeking to declare a Pennsylvania magisterial district court judgment void for lack of jurisdiction under the Rooker-Feldman doctrine.

Holdings

1. The Petition for Removal and Change of Venue and Motion for Enjoinder of Claims were moot because they were directed to the District of North Dakota, which had already transferred the case to the Western District of Pennsylvania.
2. The Rooker-Feldman doctrine deprived the federal district court of jurisdiction over Plaintiff's request to declare the state-court judgment void because Plaintiff lost in state court, complained of injuries caused by that judgment, the judgment predated the federal action, and the requested relief invited federal review and rejection of the state judgment.

Questions Presented

1. Whether Plaintiff's Petition for Removal and Change of Venue and Motion for Enjoinder of Claims were moot after the District of North Dakota transferred the case to the Western District of Pennsylvania.
2. Whether the federal district court had jurisdiction to review and declare void a prior Pennsylvania Magisterial District Court judgment.

Disposition

dismissed