McZeal v. Solon House, LLC

Background

Alfred McZeal asserted claims arising from a September 2020 judgment by the San Francisco Superior Court. That judgment ruled that a grant deed transferring the property from the Del Prado Family Trust to McZeal was void because Rene Del Prado lacked authority to transfer the property. The state court quieted title in the name of Bennett Hong, successor trustee of the Del Prado Family Trust.

McZeal alleged that he was not properly served with the state-court quiet-title proceedings or judgment and that defendants conspired to deprive him of notice, due process, and his property. He sought to void the state-court judgment and asserted claims under 42 U.S.C. §§ 1981, 1983, 1985, and 1986; the Racketeer Influenced and Corrupt Organizations Act; and California law, including claims for cancellation of a written instrument, quiet title, constructive trust, equitable estoppel, unjust enrichment, and declaratory relief.

Solon House, LLC, Jian Feng Chen, and Kelly Ruiman Chen moved to dismiss. McZeal opposed that motion and moved to strike it, arguing that it was not properly served and did not comply with a local rule. He also moved to disqualify Stephen McDonagh from representing the Solon House defendants.

Motion to Strike

The court denied the motion to strike. Even assuming there was a technical service problem, McZeal opposed the dismissal motion on its merits and showed no resulting harm or prejudice. The court also found no prejudice from the defendants’ failure to file a proposed order with their motion.

Motion to Disqualify

The court denied the motion to disqualify McDonagh. It found no apparent conflict that impaired McDonagh’s ability to represent the Solon House defendants or justified interfering with their choice of counsel. The court also noted that any prejudice from disqualification would affect the Solon House defendants rather than McZeal.

Motion to Dismiss

The court held that McZeal’s challenges to the state-court quiet-title judgment were barred by the Rooker-Feldman doctrine. That doctrine prevents a federal district court from acting as an appellate court over a state-court judgment. The court concluded that McZeal’s claims seeking to void the judgment, quiet title, impose a constructive trust, cancel the written instrument, obtain a declaration that the property belonged to him, or otherwise recover the property were collateral attacks on the state judgment. Those claims were dismissed without leave to amend.

The court also held that the fraud-based claims and conspiracy-to-defraud claims were barred by the applicable three-year statute of limitations. The court found that McZeal was asserting the same alleged lack of service and notice in state-court filings by September 2020, so the claims should have been filed by September 2023. This action was filed in May 2024. The fraud-based claims were dismissed without leave to amend.

The court separately held that McZeal’s civil-rights claims failed as a matter of law. For the claim under Section 1983, the court found that McZeal did not adequately allege a constitutional violation and that the defendants were not alleged to have acted under state authority. The court explained that being a court-appointed trustee or an attorney representing a client in state court does not, by itself, constitute acting under state authority. The court also stated that McZeal had notice of and access to state-court procedures, which defeated his due-process theory.

The court held that the Section 1985 conspiracy claim failed because McZeal did not provide facts showing when or how an agreement was formed or what acts advanced the alleged conspiracy. Because a Section 1986 claim depends on a valid Section 1985 claim, the Section 1986 claim also failed. The Section 1981 claim failed because McZeal did not allege that defendants knew he was African American or acted because of his race, and the only contract identified was the grant deed that the state court had found void.

Disposition

The court granted the motion to dismiss with prejudice and dismissed the complaint with prejudice against all defendants, including defendants who had not individually moved to dismiss. It denied McZeal’s motion to strike and motion to disqualify, entered judgment for defendants, and ordered the Clerk to close the case.