Jackman v. Members Cooperative Credit Union
- Wilhelmina Wright
- 0:20-cv-02372
- U.S. District Court · District of Minnesota
- 6
In Jackman v. Members Cooperative Credit Union, Judge Wright granted dismissal, dismissed the complaint with prejudice, and denied a trial-advancement petition as moot.
Ryan N. Jackman and Jessica K. Jackman’s federal claims were dismissed with prejudice, while Members Cooperative Credit Union prevailed on its motion to dismiss. The Jackmans’ request to advance the case for trial was denied as moot.
What happened
Ryan N. Jackman and Jessica K. Jackman sued Members Cooperative Credit Union over a mortgage, foreclosure, and the credit union’s refusal to renegotiate the loan. They sought declarations that the credit union’s mortgage practices violated federal law.
The credit union argued that an earlier state-court case involving the same mortgage and foreclosure already resolved the dispute. The federal court agreed, finding that the earlier case involved the same events and parties, ended in a final judgment, and gave the Jackmans a full and fair chance to litigate claims they raised or could have raised there.
In Jackman v. Members Cooperative Credit Union, Judge Wilhelmina M. Wright granted the credit union’s motion to dismiss and dismissed the complaint with prejudice. Judge Wright also denied the Jackmans’ petition to advance the case for trial as moot.
The detailed version
- Jackman v. Members Cooperative Credit Union · No. 0:20-cv-02372
- Wilhelmina Wright
- Aug. 19, 2021
Background
Ryan N. Jackman and Jessica K. Jackman entered into a mortgage agreement with Members Cooperative Credit Union (MCCU) on August 4, 2016, concerning residential property. The agreement gave the Jackmans a right to reinstate the mortgage if MCCU foreclosed because of missed payments. After the Jackmans defaulted in 2020, MCCU notified them that the property would be sold in foreclosure. MCCU told them they could reinstate the mortgage by paying $42,786.28. The Jackmans tried to renegotiate the mortgage, but MCCU refused. The mortgage agreement did not require MCCU to renegotiate its terms. MCCU then foreclosed, won the auction, and took possession of the property.
The Jackmans brought two claims seeking declaratory judgments under 15 U.S.C. § 1602(aa) and 15 U.S.C. §§ 1639 et seq. MCCU moved to dismiss both claims for failure to state a claim.
Res Judicata Analysis
MCCU argued that the claims were barred by res judicata, a rule that prevents a party from bringing claims that were already raised or could have been raised in an earlier case. The court applied Minnesota law because a Minnesota state court had entered the earlier judgment.
The court held that all four Minnesota res judicata requirements were satisfied:
- Same factual circumstances: The federal claims arose from the same mortgage agreement and foreclosure involved in the earlier state-court case. The court concluded that the federal claims could have been raised there.
- Same parties or persons legally connected to them: The earlier case involved the Jackmans and MCCU. It also involved Robert Kanuit, whom the court found legally connected to MCCU because he was an MCCU attorney enforcing MCCU’s legal rights.
- Final judgment on the merits: The state court entered its order on November 17, 2020, and an appellate court denied the relief sought in the Jackmans’ appeal on April 27,
- The federal court treated the state-court judgment as final and on the merits.
- Full and fair opportunity to litigate: The court found no significant procedural limitations, determined that the Jackmans had a strong incentive to litigate fully, and noted that the state court had considered the mortgage agreement and the facts alleged.
Because the claims were barred by res judicata, the court concluded that it was required to give effect to the state-court judgment and dismiss the complaint.
Order
The court granted MCCU’s motion to dismiss. It dismissed the Jackmans’ complaint with prejudice. It also denied as moot the Jackmans’ petition to advance the case for trial. The order was signed by United States District Judge Wilhelmina M. Wright.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.