Rachel Benson v. Energy Solutions Inc.

MEMORANDUM

The district court dismissed plaintiff Rachel Benson’s suit on the ground that the Rooker-Feldman doctrine deprived it of subject matter jurisdiction. We hold that the Rooker-Feldman doctrine bars Benson from proceeding and affirm that part of the district court’s judgment, but remand for the limited purpose of dismissing Benson’s case without prejudice.

In 2001, defendant Energy Solutions, Inc., filed the debt collection action against Benson that is the genesis of the present dispute, in an Arizona state court. The complaint alleged that Benson had failed to pay a debt on a. contract she had with an assignor for Energy Solutions. Although Benson was personally served with the summons and complaint, she did not respond. Energy Solutions obtained a default judgment. Five years later, Energy Solutions sought, and was subsequently granted, a renewal of its judgment against Benson. Energy Solutions obtained a second renewal of its judgment against Benson in 2011. By this time, the amount owed stood at $4,729,15. In 2012, Energy Solutions sought a writ of garnishment for Benson’s Bank of America account, which the state court granted.

Nearly a year later, and almost…