Liu v. Fidelity National Title Company
- Kandis Westmore
- 3:25-cv-03728
- U.S. District Court · Northern District of California
- 2
In Steven Liu v. Fidelity National Title Company, Judge Donato dismissed the case for lack of standing and failure to state a claim.
Steven Liu’s case was dismissed at the screening stage for lack of standing and failure to state a claim. The court also denied BayMark Financial, Inc.’s pending motion to dismiss as moot.
What happened
Steven Liu, representing himself, sued Fidelity National Title Company and others over the foreclosure of his sister’s property and unlawful-detainer actions against him and his sister.
The magistrate judge found that Liu’s amended complaint did not show that he had standing to sue or plausibly state a claim, and recommended dismissal because the complaint was frivolous under federal screening law. Liu objected, but his objections did not correct those problems.
Judge James Donato adopted the recommendation in full, dismissed the case for lack of standing and failure to state a claim, and closed the case. The court also denied BayMark Financial, Inc.’s pending motion to dismiss as moot and vacated the scheduled hearing.
The detailed version
- Liu v. Fidelity National Title Company · No. 3:25-cv-03728
- Kandis Westmore
- Oct. 3, 2025
Background
Steven Liu, a self-represented plaintiff, filed claims concerning the foreclosure of his sister’s property and later unlawful-detainer actions against Liu and his sister. The magistrate judge initially screened the complaint and found that it failed to comply with Federal Rules of Civil Procedure 8 and 12. Liu was allowed to file an amended complaint.
Liu filed a first amended complaint. The magistrate judge concluded that it still did not establish standing—the legal requirement that a plaintiff show a sufficient personal connection to the dispute—and did not plausibly state a claim. The magistrate judge recommended dismissal because the amended complaint was frivolous under 28 U.S.C. § 1915(e)(2).
Objections
Liu filed a document titled “Opposition to the Magistrate Judge’s Finding and Recommendation.” The court treated it as a timely objection, although it did not specifically respond to the recommendation as required by Federal Rule of Civil Procedure 72(b)(2). The objections mainly repeated Liu’s opposition to BayMark Financial, Inc.’s motion to dismiss and included generalized criticism of the magistrate judge.
Liu argued that he had standing because he was a tenant in the foreclosed property. The court said the authority he cited did not support that argument. The court also found that Liu’s statement that the alleged deficiencies in the Racketeer Influenced and Corrupt Organizations portion of the lawsuit could be fixed did not meaningfully address the pleading problems and was inaccurate regarding the allegations in the amended complaint.
Ruling
After independently reviewing the record and the magistrate judge’s recommendation, Judge James Donato adopted the recommendation in full. The court ruled that dismissal was warranted for lack of standing and failure to state a claim. It concluded that further amendment was not warranted because Liu had received multiple opportunities to present his claims and guidance about the deficiencies in his pleadings.
The case was closed. The court denied BayMark Financial, Inc.’s pending motion to dismiss as moot and vacated the hearing scheduled for October 9, 2025. The opinion does not specify whether the dismissal was with or without prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.