Shi v. Delta Realty Group, LLC

Background

Shuanglong Shi, proceeding without a lawyer, sued Delta Realty Group, LLC over a prior commercial nonpayment eviction proceeding involving a rental property. In that state-court proceeding, Shi asserted counterclaims concerning the alleged lease, the rental property, personal and financial information, and alleged fraud and harm to his reputation and finances. The Bronx Civil Court entered judgment for Delta, awarded Delta $126,160.00, granted Delta possession of the property, ordered an eviction warrant to issue, and dismissed Shi’s counterclaims. The opinion states that Delta ultimately recovered $113,186.31 toward the judgment.

Shi’s federal complaint and amended complaint repeated many of those allegations. He also alleged that Delta took more money from his bank accounts than the state-court judgment allowed and sought approximately $600,000 in damages. The opinion notes discrepancies between Shi’s allegations and the record about the amount taken and when withdrawals occurred, but states that those discrepancies did not affect the ruling.

Rooker-Feldman ruling

The court held that Shi’s claim concerning money taken from his bank accounts was barred by the Rooker-Feldman doctrine. That doctrine prevents federal district courts from acting as appeals courts reviewing state-court judgments. The court found that Shi had lost in state court, the state judgment came before he filed his federal complaint, the injury he alleged resulted from that judgment and efforts to enforce it, and his requested relief would require review or rejection of the state-court judgment. The court therefore concluded that it lacked subject-matter jurisdiction over that claim and granted Delta summary judgment on it.

The court also stated that allegations that a state-court judgment was obtained through fraud did not avoid the doctrine here because Shi’s alleged injuries were tied to the prior proceeding, its judgment, and enforcement efforts.

Claim-preclusion ruling

The court applied New York’s claim-preclusion rule, also called res judicata. Claim preclusion prevents a party from bringing a later case based on the same factual grouping when an earlier case involving the same parties ended with a decision on the merits, including claims that were or could have been raised earlier.

The court found that the prior eviction proceeding was decided on the merits after a trial and involved the same opposing parties. It further found that Shi’s remaining federal claims arose from the same alleged lease and eviction-related facts. Most of those claims had already been asserted as counterclaims, and the remaining claims—that Shi had not engaged in business activity with Delta and did not previously know Delta or its owner—could have been raised in the earlier proceeding. The court therefore held that res judicata barred the remaining claims and granted Delta summary judgment on them.

Claims involving nonparties

The court construed the amended complaint as attempting to assert claims for Lifeng Jin and Wenzhu Lou, who were not parties to the case. It explained that a person representing himself may litigate only his own interests and may not represent another person in court. The court dismissed without prejudice any claims Shi attempted to bring on behalf of those individuals. It declined to construe the complaint as asserting claims against them because the opinion found it unclear how the allegations concerning them were actionable or related to Shi’s claims.

Shi’s motion and amendment

Shi filed a motion instead of an opposition to Delta’s summary-judgment motion. Construed liberally, the motion repeated some prior claims, asserted additional claims for the nonparties, and raised possible new claims related to the eviction proceeding and state-court judgment. The court concluded that the repeated claims and claims for nonparties failed for the reasons already discussed. It also ruled that new claims could not properly be raised for the first time in opposition to summary judgment and, in any event, would be barred by claim preclusion. The court denied Shi’s motion.

The court declined to allow Shi to amend his complaint because it concluded that the defects in his claims against Delta could not be cured by amendment.

Disposition

Judge Dale E. Ho granted Delta’s motion for summary judgment and denied Shi’s motion. The court dismissed without prejudice the claims Shi attempted to bring on behalf of Lifeng Jin and Wenzhu Lou, declined leave to amend the claims against Delta, and directed the clerk to close the case. The court did not reach Delta’s additional arguments concerning issue preclusion or whether the evidence independently warranted summary judgment.

The court also stated that Shi had filed his motion under seal without first requesting permission. It allowed him until July 30, 2025, to file a letter asking that the motion remain sealed and explaining why. If he did not do so, the court stated that it would order the motion unsealed.