Briks v. Smith, Strege, Fredericksen, Butts, & Clark, Ltd

Background

James Briks and Jerome Briks filed this action without lawyers against Smith, Stege, Fredericksen, Butts, & Clark, Ltd, and Richard E.T. Smith. Their amended complaint asserted negligence, described as a legal-malpractice claim. The plaintiffs alleged that their brother, Donald Briks, died on September 9, 2010, and that the defendants had established a trust for him in 1992 and improperly placed certain property in it.

The plaintiffs had previously filed a legal-malpractice action against the defendants in Wilkin County District Court. That court granted the defendants’ motion for summary judgment and entered judgment for the defendants in December 2018. The Minnesota Court of Appeals affirmed, and the Minnesota Supreme Court denied further review. The Minnesota Court of Appeals entered judgment on October 17, 2019.

The federal amended complaint appeared to be the same document the plaintiffs had filed in state court. The defendants moved to dismiss, arguing that the federal court lacked subject-matter jurisdiction because the negligence claim was identical to the claim previously litigated in state court.

Analysis

The magistrate judge recommended dismissal under the Rooker-Feldman doctrine. This doctrine generally bars a federal district court from directly reviewing a state-court judgment or deciding a claim that is so closely connected to that judgment that the federal claim could succeed only if the state court had wrongly decided the issues.

The district court reviewed the plaintiffs’ specific objections independently and reviewed the remaining portions of the recommendation for clear error. The court concluded that the plaintiffs were trying to relitigate the previously decided state-court matter. Because their legal-malpractice claim could succeed only if the state court had wrongly decided the issue, the federal court held that it lacked subject-matter jurisdiction.

The court also found that the plaintiffs’ other objections lacked sufficient factual or legal specificity. It determined that the report and recommendation was neither clearly erroneous nor contrary to law.

Disposition

The court overruled the plaintiffs’ objections, adopted the January 21, 2020 report and recommendation in its entirety, granted the defendants’ motion to dismiss, and dismissed the amended complaint without prejudice. The dismissal was for lack of subject-matter jurisdiction.