Rheta Negrete-Neal, et al. v. Anthony Luraschi, Executor of the Estate of John Bellisomi, et al.

Summary

The United States District Court for the Western District of Tennessee adopts a magistrate judge’s Report and Recommendation and dismisses the plaintiffs’ amended complaint with prejudice. The court concludes that the probate exception to federal jurisdiction and the Rooker-Feldman doctrine deprive it of subject matter jurisdiction because the plaintiffs seek to relitigate state probate proceedings and determine rights in disputed estate property. No party objected to the Report and Recommendation, so the court reviewed it for clear error.

Holdings

1. The probate exception deprived the district court of subject matter jurisdiction because plaintiffs sought relief that would disturb or affect property in the custody or control of state probate proceedings, including a declaration of estate interests and partition of the disputed parcels.
2. The Rooker-Feldman doctrine deprived the district court of subject matter jurisdiction because plaintiffs were state-court losers complaining of injuries caused by probate-court judgments and sought relief that was the functional equivalent of an appeal or collateral attack on those judgments.
3. The district court adopted the magistrate judge's report and recommendation after finding no clear error because no party filed objections within fourteen days.

Questions Presented

1. Whether the probate exception to federal jurisdiction deprived the district court of subject matter jurisdiction over plaintiffs' claims seeking to determine interests in estate property and partition disputed parcels.
2. Whether the Rooker-Feldman doctrine deprived the district court of subject matter jurisdiction because plaintiffs' claims were the functional equivalent of an appeal or collateral attack on Shelby County Probate Court judgments.
3. Whether the magistrate judge's report and recommendation should be adopted when no party filed objections and the district court found no clear error.

Disposition

dismissed