Rogers v. U.S. Bank National Associations
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Opinion
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
BARBARA HANNAH ROGERS, ) ) Plaintiff, ) ) v. ) Civil Action No. 24-3193 (UNA) ) U.S. BANK NATIONAL ASSOCIATION, et al., ) ) Defendants. )
MEMORANDUM OPINION
This matter is before the Court on Plaintiff’s application to proceed in forma pauperis
(ECF No. 2) and her pro se Complaint (ECF No. 1).1 It appears that Plaintiff has an interest in
real property in Effingham, South Carolina. She purports to assert a claim under 42 U.S.C. §
1983 for alleged violations of her rights under the United States Constitution. See Compl. at 3,
4. Her claims pertain to foreclosure proceedings in the Court of Common Pleas, State of South
Carolina, County of Florence, culminating in a judgment of foreclosure in the mortgagee’s favor
and an order for the sale of the property at public auction, see generally Compl., Ex. (ECF No. 1-
1), set for December 3, 2024, see id. at 4. Among other relief, Plaintiff demands “free and clear
title” to the property. Id. at 5. In addition, Plaintiff appears to challenge the ruling of the United
States District Court for the District of South Carolina, see id. at 4, dismissing Plaintiff’s prior
challenge to the South Carolina proceedings, see id., Ex. (ECF No. 1-1 at 32-35).
This Court lacks jurisdiction to provide Plaintiff’s requested relief. See Kokkonen v.
Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (“Federal Courts are courts of limited
1 Only Barbara Hannah Rogers filed an application to proceed in forma pauperis, and only she is listed as a plaintiff in the Complaint. The Court proceeds as if she is the sole plaintiff. 1 jurisdiction. They possess only that power authorized by Constitution and statute.”); NetworkIP,
LLC v. FCC, 548 F.3d 116, 120 (D.C. Cir. 2008) (“It is axiomatic that subject matter jurisdiction
may not be waived, and that courts may raise the issue sua sponte.”). As a general rule, a federal
district court lacks jurisdiction to review the decisions of other courts. See, e.g., Petrovic v.
United States, No. 1:19-cv-00482, 2019 WL 1746301, at *2 (D.D.C. Apr. 17, 2019); United
States v. Choi, 818 F. Supp. 2d 79, 85 (D.D.C. 2011) (citing Lewis v. Green, 629 F. Supp. 546,
553 (D.D.C. 1986)); Fleming v. United States, 847 F. Supp. 170, 172 (D.D.C. 1994) (applying
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983)); Rooker v. Fidelity
Trust Co., 263 U.S. 413, 415, 416 (1923); see also Prentice v. U.S. Dist. Court for E. Dist. of
Mich., 307 F. App’x 460, 460 (D.C. Cir. 2008) (per curiam) (“[B]ecause a challenge to a state
court action must proceed through that state’s system of appellate review rather than through a
federal district court, the district court properly determined it lacked jurisdiction to review action
taken by a . . . state court.” (citations omitted)).
Here, if this Court were to entertain the Plaintiff’s claims, it would necessarily need to
review and overturn rulings of a South Carolina court and a sister federal district court over
which it lacks jurisdiction. Thus, the Court dismisses the Complaint without prejudice for lack
of subject matter jurisdiction and grants Plaintiff’s application to proceed in forma pauperis. An
Order is issued separately.
DATE: November 21, 2024 ANA C. REYES United States District Judge
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