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|DANIEL VANDERKODDE; SUSAN BUCK; RUBY ROBINSON; ANITA
BECKLEY; RITCHIE SWAGERTY, on behalf of themselves and all others
MARY JANE M. ELLIOTT, P.C. (19-1091/1127); BERNDT & ASSOCIATES,
LVNV FUNDING, LLC; MIDLAND FUNDING, LLC; MIDLAND CREDIT
MANAGEMENT, INC.; ENCORE CAPITAL GROUP, INC.,
| Nos. 19-1091/1127/1128|
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 1:17-cv-00203—Paul Lewis Maloney, District Judge.
Argued: January 29, 2020
Decided and Filed: February 26, 2020
Before: GUY, SUTTON, and GRIFFIN, Circuit Judges.
In Exxon Mobil Corp. v. Saudi Basic Industries Corp., the Supreme Court made clear that
the Rooker-Feldman doctrine—which prohibits the lower federal courts from reviewing appeals
of state-court decisions—applies only to an exceedingly narrow set of cases. 544 U.S. 280
(2005). This putative class action brought under the Fair Debt Collection Practices Act and
Michigan consumer laws “is not the rare one that threads the Rooker-Feldman needle.” Van
Hoven v. Buckles & Buckles, P.L.C., 947 F.3d 889, 892 (6th Cir. 2020). We therefore reverse its
dismissal on Rooker-Feldman grounds and remand for further proceedings.