Westby Co-Op Credit Union v. Trails End Motel, LLC, Antoine Samuel Wilson, Sr., Karen Frances Wilson, Columbia County, WR Stewart & Associates, S.C., and Department of Revenue

Summary

The United States District Court for the Western District of Wisconsin remanded a removed state foreclosure action for lack of subject-matter jurisdiction. The court held that the foreclosure claim presented a state-law matter, diversity jurisdiction was not established, and the Rooker-Feldman doctrine barred federal review of the state foreclosure judgment. The court denied the defendants’ pending motions, including motions to seal the record, as moot or unsupported.

Holdings

1. The removed foreclosure action did not arise under federal law because it was a state-law foreclosure matter.
2. The defendants failed to establish diversity jurisdiction over the foreclosure action.
3. The federal district court lacked jurisdiction to overturn the state court's foreclosure judgment under the Rooker-Feldman doctrine.
4. The defendants' proposed federal civil-rights and RICO-related counterclaims could not establish federal-question jurisdiction over the removed action.
5. The case had to be remanded to state court for lack of subject matter jurisdiction.

Questions Presented

1. Whether the federal district court had original federal-question or diversity jurisdiction over the removed state foreclosure action.
2. Whether the federal district court could review or overturn the state court's foreclosure judgment under the Rooker-Feldman doctrine.
3. Whether the defendants' proposed federal counterclaims or additional pleading could establish federal jurisdiction over the removed action.
4. Whether the defendants' pending motions should be resolved after the case was remanded.

Disposition

remanded