In re: EILEEN T. ADAMS v. McKenna, 948 F.3d 105, 116 3d Cir. 2020 , we affirm the Bankruptcy Court’s

PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
___________
No. 24-1212
In re: EILEEN T. ADAMS,
Appellant
On Appeal from the United States District Court
for the District of New Jersey
(District Court No. 1:22-cv-06256)
District Judge: Honorable Karen M. Williams
Submitted Under Third Circuit L.A.R. 34.1(a)
on March 24, 2025
Before: BIBAS, PHIPPS, and AMBRO, Circuit Judges
(Opinion filed: September 3, 2025)
David A. Kasen
KASEN & KASEN
1874 E Marlton Pike
Suite 3
Cherry Hill, NJ 08003
Counsel for Appellant

-- 1 of 20 --

2
Barbara A. Fein
STERN LAVINTHAL & FRANKENBERG
103 Eisenhower Parkway
Suite 100
Roseland, NJ 07068
Joseph I. Foley
MCCABE WEISBERG & CONWAY
216 Haddon Avenue
Suite 201
Westmont, NJ 08108
James A. French, Esq.
MARKS O’NEILL O’BRIEN DOHERTY & KELLY
535 Route 38 East
Suite 501
Cherry Hill, NJ 08002
Counsel for Appellee
OPINION OF THE COURT
AMBRO, Circuit Judge
When the bank foreclosed the mortgage on their home,
Eileen Adams and her husband fought back. They filed for
bankruptcy again and again, hoping to use the protections of
bankruptcy law to stave off a foreclosure sale. At the same
time, they relitigated the foreclosure judgment in New Jersey

-- 2 of 20 --

3
state court. Adams and her husband lost their state-court
appeal, and the Supreme Court of New Jersey declined review.
Then Adams filed for bankruptcy once more. This appeal
comes from that case.
The Bankruptcy Court granted Nationstar Mortgage’s
motion to lift the bankruptcy protections so it could sell the
house. Adams opposed that motion, making all the same
arguments she had made in New Jersey state courts. The
Bankruptcy Court ruled for Nationstar, so Adams appealed to
the District Court. That Court, understanding Adams was
rehashing the state-court litigation, affirmed the Bankruptcy
Court’s order and dismissed the appeal for lack of jurisdiction
under the Rooker-Feldman doctrine.
We agree Adams loses, but not for that reason. Rather,
it is because despite all their efforts, she and her husband have
lost, finally and on the merits. We do have jurisdiction, and we
exercise it to hold that her claims are precluded. Because “we
may affirm on any ground supported by the record,” Laurel
Gardens, LLC v. McKenna, 948 F.3d 105, 116 (3d Cir. 2020),
we affirm the Bankruptcy Court’s order lifting the automatic
stay and use this opportunity to offer guidance on the
application of Rooker-Feldman in bankruptcy.
I. BACKGROUND
The relevant facts are undisputed and fairly brief.
In 2008, Adams and her husband gave their New Jersey
home to her father. The next year, the father borrowed
$360,000 from AmTrust Bank, securing it with a mortgage
against the home in favor of Mortgage Electronic Registration

-- 3 of 20 --

4
Systems (MERS), AmTrust’s nominee. Sadly, he died soon
after, leaving the home back to Adams, who took it subject to
the mortgage. Complicating matters further, AmTrust failed
not long after that and fell into FDIC receivership. The New
York Community Bank (NYCB) acquired substantially all of
AmTrust’s assets and liabilities, but the evidence is unclear, at
best, whether Adams’s mortgage was meant to be part of that
transfer.
Either way, it was MERS, not NYCB, that assigned the
mortgage to another lender, EverBank, in November 2013.
EverBank recorded the assignment. Adams had defaulted on
the mortgage just before the assignment, in August 2013, so
EverBank filed a complaint of foreclosure in August 2014.
Adams answered the complaint pro se. But she did not oppose
EverBank’s later motion for summary judgment, which the
state trial court granted in October 2015. Not long after,
EverBank assigned the mortgage to our Appellee, Nationstar
Mortgage, but EverBank continued to litigate the foreclosure
without a formal substitution of parties.
Even so, Nationstar, holding itself out as EverBank’s
servicer, supported EverBank’s motion for an entry of final
judgment, granted in March 2017. The same day, Adams and
her husband filed for Chapter 7 bankruptcy, later receiving a
discharge before the case was dismissed in September 2017.
The year after, Adams filed a Chapter 13 petition, and that
bankruptcy court granted her leave to challenge the state-court
foreclosure judgment.
So she did. Over the next two years, Adams exhausted
her state-court remedies: in 2019, the trial court denied her
motion to reconsider the final judgment of foreclosure, ruling

-- 4 of 20 --

5
that EverBank held the note and could foreclose the mortgage;
the Appellate Division affirmed that order in 2020; and soon
after, the Supreme Court of New Jersey denied her
discretionary appeal.
Affirming the trial court’s denial of reconsideration, the
Appellate Division held that (1) under New Jersey law, either
“possession of the note or an assignment of the mortgage that
predated the original [foreclosure] complaint confer[s]
standing” in a foreclosure action, and (2) even if somewhere
along the chain of custody the mortgage or note were
improperly assigned, Adams did not have standing to challenge
that assignment. (emphasis added) (citations omitted).
Throughout the state-court proceedings, Adams and her
husband argued EverBank could not foreclose the mortgage
because it did not hold it—they believed it had been transferred
to NYCB when it took over AmTrusts’s assets and liabilities.
For our purposes, we are satisfied that those questions, plus
others concerning any other convoluted path of ownership or
assignment the Adams mortgage might have taken, were
litigated to a final judgment on the merits in the lengthy
foreclosure proceedings.
In 2019, after the trial court denied her motion for
reconsideration, Adams withdrew her Chapter 13 petition, but
her husband filed a Chapter 13 petition in 2021, and she filed
one of her own in 2022—all surely to fend off the impending
foreclosure sale.
We are here as part of Adams’s 2022 Chapter 13 case.
Nationstar moved for in rem relief from the automatic stay,
which the Bankruptcy Court granted. Adams appealed to the
District Court. Throughout, she again challenged whether

-- 5 of 20 --

6
EverBank (or Nationstar) had standing in the state-court
foreclosure proceedings as a proper holder of the mortgage
with the right to foreclose. But the District Court affirmed the
Bankruptcy Court, then dismissed the appeal for lack of
jurisdiction on Rooker-Feldman grounds, reasoning that
Adams was asking the federal courts to void a previously
entered state-court judgment.
Adams timely appealed in February 2024. Three
months later, she and her husband paid more than $400,000 at
the sheriff’s foreclosure sale to buy back the house.
II. JURISDICTION AND STANDARD OF REVIEW
The Bankruptcy Court had jurisdiction under 28 U.S.C.
§§ 157(b) and 1334(b), the District Court had jurisdiction
under 28 U.S.C. § 158(a), and we have jurisdiction over the
District Court’s order under 28 U.S.C. §§ 158(d) and 1291.
Though this is an appeal of a District Court decision, we
review the Bankruptcy Court’s decision “unfettered” by the
District Court ruling. In re Gilbert, 120 F.4th 114, 121 (3d Cir.
2024) (quotation omitted). In doing so, we review the
Bankruptcy Court’s decision to lift the stay for abuse of
discretion. In re Myers, 491 F.3d 120, 128 (3d Cir. 2007). Its
application of the Rooker-Feldman doctrine is a conclusion of
law, which we review de novo. In re Heritage Highgate, Inc.,
679 F.3d 132, 139 (3d Cir. 2012).
III. ANALYSIS
To resolve this case, we work through a brief refresher
on the Rooker-Feldman doctrine, offer some observations on

-- 6 of 20 --

7
the application of Rooker-Feldman in bankruptcy, and explain
why preclusion, not Rooker-Feldman, prohibits Adams’s
claims.
A. Rooker-Feldman and preclusion look similar at a
glance, but they have distinct purposes and
applications.
By its constitutional authority, Congress endows the
district courts with jurisdiction. U.S. Const. art. III, § 1. Many
of those provisions are well-worn and familiar. See, e.g., 28
U.S.C. § 1331 (federal-question jurisdiction); § 1332 (diversity
jurisdiction); § 1334 (bankruptcy jurisdiction). And through
that same authority, Congress vests the Supreme Court, and the
Supreme Court alone, with appellate jurisdiction over “[f]inal
judgments or decrees” of state supreme courts. Id. § 1257.
As we will explain, Rooker-Feldman is triggered only
when a plaintiff flouts that grant of appellate jurisdiction to the
Supreme Court, not every time a litigant seeks a re-do of a
state-court decision.
1. The Rooker-Feldman doctrine enforces a
limitation on federal appellate
jurisdiction.
The Rooker-Feldman doctrine takes its name from two
Supreme Court cases policing the boundary between the
original jurisdiction of the district courts and the appellate
jurisdiction of the Supreme Court.
In Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923),
the petitioners had gone to federal district court to ask that an
Indiana state-court judgment be “declared null and void” on

-- 7 of 20 --

8
the ground that it was unconstitutional. Id. at 414–15. The
District Court dismissed the suit as outside its jurisdiction. Id.
at 415. The Supreme Court agreed, explaining that, by statute,
“no court of the United States other than th[at] [C]ourt could
entertain a proceeding to reverse or modify the judgment for
errors of [constitutional] character.” Id. at 416. Doing so
“would be an exercise of appellate jurisdiction,” but a district
court’s jurisdiction “is strictly original.” Id.
Sixty years passed before the Supreme Court returned
to this issue in District of Columbia Court of Appeals v.
Feldman, 460 U.S. 462 (1983). The federal plaintiffs there
were aspiring lawyers who petitioned the D.C. Court of
Appeals, that jurisdiction’s highest court, to waive certain bar-
admission requirements so that they could sit for the bar exam.
Id. at 463. When that Court denied their petitions, they sued
separately in federal district court to challenge the decision. Id.
at 468–72. In both cases, the District Court dismissed the suit,
reasoning, as did the District Court in Rooker, that an appeal of
the D.C. high court’s opinion could be heard only in the
Supreme Court. Id. at 470, 472–73.
The Supreme Court agreed, to an extent. Id. at 486–87.
It explained that some of the plaintiffs’ allegations about their
eligibility to sit for the bar exam—that the D.C. Court of
Appeals had acted “arbitrarily and capriciously” and
“unreasonably and discriminatorily” in denying their
petitions—were “inextricably intertwined” with their
challenge to that Court’s judgment. Id. at 486–87 (emphasis
added). Those allegations, in effect, sought a direct review of
the D.C. Court of Appeals’ judgment, an appeal that could be
taken only in the Supreme Court. Id. at 487. But the Feldman
Court also ruled that the plaintiffs’ “general attack on the

-- 8 of 20 --

9
constitutionality” of the bar-admission requirements could
proceed, as through that challenge they were not seeking
“review of a final state court judgment in a particular case.” Id.
at 482, 486–87. Complicating matters, in a footnote, the Court
explained that a district court would still lack jurisdiction when
any “constitutional claims presented . . . are inextricably
intertwined with the state court’s denial in a judicial
proceeding of a particular plaintiff’s application for admission
to the state bar.” Id. at 482 n.16 (emphasis added).
Years passed, and mischief ensued as “the lower courts”
“[v]ariously interpreted” the Rooker-Feldman doctrine “to
extend far beyond the contours of
the Rooker and Feldman cases, overriding Congress’ conferral
of federal-court jurisdiction concurrent with jurisdiction
exercised by state court.” Exxon Mobil Corp. v. Saudi Basic
Indus., 544 U.S. 280, 283 (2005). The decision reviewed in
Exxon Mobil was one of our own, in which we ruled that the
entry of a state-court verdict for ExxonMobil barred a federal
district court’s jurisdiction over parallel proceedings “because
ExxonMobil’s claims ha[d] already been litigated in state
court.” Id. at 290 (quotation omitted). We had reasoned that
should the federal suit proceed, it could have the effect of
“invalidat[ing] the state-court judgment, the very situation . . .
contemplated by Rooker-Feldman’s ‘inextricably intertwined’
bar.” Id. at 291 (cleaned up).
The Supreme Court reversed, explaining we had
misapplied Rooker-Feldman, as “federal jurisdiction over an
action does not terminate automatically on the entry of
judgment in the state court.” Id. at 293. True, doctrines of
“[c]omity or abstention” may “permit or require the federal
court to stay or dismiss the federal action in favor of” pendent

-- 9 of 20 --

10
“state-court litigation,” id. at 292, and “preclusion law”—
much more on that below—may “govern[]” the federal
proceedings “once the state-court adjudication is complete,” id.
at 293. But the Court issued a forceful reminder. The Rooker-
Feldman doctrine is “confined” to a limited set of cases: those
“brought by state-court losers complaining of injuries caused
by state-court judgments rendered before the district court
proceedings commenced and inviting district court review and
rejection of those judgments.” Id. at 284.
Today, in light of the doctrine’s development, we too
emphasize that Rooker-Feldman captures only a simple, if not
elusive, rule of federal jurisdiction. The certiorari statute, 28
U.S.C. § 1257, means what it says: an action that is, or is in
effect, an appeal of a state-court judgment may not be lodged
in any federal court but the Supreme Court.1 This narrow rule
thus has narrow application, and it does not “supersed[e] the
ordinary application of preclusion law” when a plaintiff
relitigates a matter decided in another forum. Exxon Mobil, 544
U.S. at 281. We turn there next.
1 To be sure, a common manner of challenging a state-court
judgment is through federal habeas proceedings. But that is a
collateral attack, not the kind of direct appeal barred by the
Rooker-Feldman doctrine. Wall v. Kholi, 562 U.S. 545, 552
(2011) (“We have previously described a variety of
proceedings as ‘collateral,’ and all of these proceedings share
the characteristic that we have identified, i.e., they stand apart
from the process of direct review. For example, our cases make
it clear that habeas corpus is a form of collateral review.”).

-- 10 of 20 --

11
2. Preclusion, not Rooker-Feldman, is what
typically prohibits a plaintiff’s efforts to
have her claims relitigated.
Of course, the kind of case that triggers Rooker-
Feldman necessarily involves a plaintiff who wants another go
at it. Unhappy with her state-court results, she comes to the
federal district court to try again. But imagine a legal system in
which that were a winning strategy: If you whiff in state court,
take your mulligan and come to federal court for another
swing. State-court judgments would be near-worthless. To
ensure those judgments receive the full faith and credit
promised by the Constitution, art. IV, § 1, and to safeguard the
efficiency and finality of litigation, we apply principles of
preclusion.
Preclusion comes in two kinds: claim and issue. As both
commonly prohibit the relitigation of claims and issues
previously decided, they are sometimes together referred to as
res judicata—that is, a matter already decided. Taylor v.
Sturgell, 553 U.S. 880, 891–92 (2008). “Theoreticians of
[procedure] have enjoyed countless hours delighting in the
intricate rules of res judicata,” or preclusion. 18 Wright &
Miller’s Federal Practice & Procedure § 4401 (3d ed. 2025).2
For our purposes, it suffices to say just a few things.
2 Confusingly, “res judicata” is used to refer to both the pair of
claim and issue preclusion and sometimes claim preclusion
alone. United States v. Weiss, 52 F.4th 546, 551 n.4 (3d Cir.
2022). We use “res judicata” here as the catch-all term for both
kinds of preclusion.

-- 11 of 20 --

12
“Under the doctrine of claim preclusion,” a prior “final
judgment forecloses ‘successive litigation of the very same
claim.’” Taylor, 553 U.S. at 892 (quoting New Hampshire v.
Maine, 532 U.S. 742, 748 (2001)). A hypothetical will
illustrate. Allison sues Bob in state court, claiming his reckless
driving caused her injuries when their cars collided. After a
bench trial, the state-court judge rules for Bob. If Allsion were
to then go to another court—say, federal district court—to sue
Bob again for the accident, claim preclusion would apply to bar
her lawsuit.
Issue preclusion, on the other hand, “bars ‘successive
litigation of an issue of fact or law’” that was “‘actually
litigated[,] resolved in a valid court determination[, and]
essential to th[at] prior judgment,’ even if the issue recurs in
the context of a different claim.” Id. (quoting New Hampshire,
532 U.S. at 748–49). Back to our hypothetical. In that state-
court trial, Bob countersued Allison, claiming she was driving
recklessly, not him. And the judge, when ruling for Bob, found
that she was. Afterward, Allison’s car insurer cancels her
policy. She sues to restore coverage, arguing she was not
driving recklessly—that it was a true accident. Issue preclusion
prohibits her from making that argument, because the legal
issue of Allison’s recklessness was essential to the judgment
for Bob and was actually litigated—meaning resolved on the
merits, not dismissed on some procedural ground—in state
court.3
3 Careful readers will spot that Allison was a party to the prior
state-court action, avoiding any impermissible nonmutual
issue preclusion. In the interest of simplicity, we do not wade
into those waters.

-- 12 of 20 --

13
Given these examples, it is easy to imagine how a matter
barred by preclusion—a suit in district court, for example, that
attempts to relitigate a prior state-court claim—looks a lot like
something that might offend Rooker-Feldman. In all instances,
a litigant comes to federal court to try again. But “Rooker-
Feldman is not simply preclusion by another name.” Lance v.
Dennis, 546 U.S. 459, 466 (2006) (per curiam). The doctrine
does not “supersed[e] the ordinary application of preclusion
law under” principles of full faith and credit, which, as codified
at 28 U.S.C. § 1738, require federal courts to “give the same
preclusive effect to a state-court judgment as another court of
that State would give.” Exxon Mobil, 544 U.S. at 283, 293
(quoting Parsons Steel, Inc. v. First Alabama Bank, 474 U.S.
518, 523 (1986)). So it follows that Rooker-Feldman does not
“stop a district court from exercising subject-matter
jurisdiction simply because a party attempts to litigate in
federal court a matter [precluded because it was] previously
litigated in state court.” Id. at 293. As a jurisdictional doctrine,
Rooker-Feldman requires we ask whether the plaintiff has a
permissible reason—a valid jurisdictional ground—to be in
district court at all.
Put another way, preclusion stops a litigant from taking
another bite at the apple. But Rooker-Feldman, to extend the
metaphor, tells a would-be plaintiff she may lodge her
complaints about the state-court produce only in the Supreme
Court, not district court. Though the reasons why differ, both
doctrines deny the fruit of her efforts.

-- 13 of 20 --

14
B. Rooker-Feldman applies the same in bankruptcy.
“[B]ankruptcy is different” from ordinary “civil
litigation,” because “[a] bankruptcy case [is] an aggregation of
individual controversies.” Ritzen Grp., Inc. v. Jackson
Masonry, LLC, 589 U.S. 35, 37 (2020) (cleaned up). Though
28 U.S.C. § 1334 “vests broad primary jurisdiction over
bankruptcy proceedings in the [d]istrict [c]ourts,” quite
“routinely” those courts “refer bankruptcy matters falling
within their jurisdiction to the [b]ankruptcy [c]ourts under 28
U.S.C. § 157(a).” Halper v. Halper, 164 F.3d 830, 836 (3d Cir.
1999) (quotation omitted). The bankruptcy courts, in turn,
apply Title 11’s panoply of procedural and substantive powers
to resolve bankruptcy cases.
“The cases are unanimous that as a general matter
Rooker-Feldman is applicable in bankruptcy courts.” 1 Collier
on Bankruptcy ¶ 3.02 (16th ed. 2025) (collecting cases). This
makes good sense, as bankruptcy courts exercise federal
jurisdiction. But in an “apparent contradiction to Rooker-
Feldman,” those “bankruptcy courts are empowered to avoid
state judgments, see, e.g., 11 U.S.C. §§ 544, 547, 548, 549; to
modify them, see, e.g., 11 U.S.C. §§ 1129, 1325; and to
discharge them, see, e.g., 11 U.S.C. §§ 727, 1141, 1328.” In re
Knapper, 407 F.3d 573, 583 n.22 (3d Cir. 2005) (quoting In re
Gruntz, 202 F.3d 1074, 1079 (9th Cir. 2000) (en banc)).
Despite this “apparent contradiction,” appearances are
not what they seem. True enough, when parties come to the
bankruptcy court to “restructur[e] . . . debtor-creditor
relations”—the purpose “at the core of the federal bankruptcy
power”—state-court judgments are swept into the dealings.
Halper, 164 F.3d at 835–36 (quotation omitted). Creditors and

-- 14 of 20 --

15
debtors alike, all harnessing the substantive powers of the
Bankruptcy Code, may assert claims that “den[y] a legal
conclusion that a state court has reached”—the scope of a lien,
the amount of a judgment, or, as Adams here, the validity of a
foreclosure. Exxon Mobil, 544 U.S. at 293 (quotation omitted).
But those bankruptcy-court powers over state-court judgments
are not based on separate invocations of jurisdiction that
violate Rooker-Feldman. Each, if properly asserted, falls under
the grant of bankruptcy court jurisdiction in 28 U.S.C. § 1334.
And each, again if properly asserted, lays claim to some
independent bankruptcy-court power contained in Title 11.
Thus, in bankruptcy, Rooker-Feldman applies only
when two additional conditions are met: (a) procedurally, the
claim is alleged as part of an adversary proceeding (i.e., a
complaint under Federal Rule of Bankruptcy Procedure 7003);
and (b) the federal bankruptcy plaintiff’s claim, even if “one
that denies a legal conclusion that a state court has reached in
a case to which [the plaintiff] was a party,” is not otherwise
“independent” of her state-court claims. Exxon Mobil, 544 U.S.
at 293 (quotation omitted).
As an example, consider our decision in In re
Philadelphia Entertainment & Development Partners, 879
F.3d 492 (3d Cir. 2018). In 2006, Pennsylvania awarded a slot
machine license to a casino partnership in exchange for a $50
million fee. When the partnership failed to meet the remaining
licensing requirements, the Commonwealth revoked the
license, requiring the partnership to transfer it back. The
partners appealed that decision fully through the Supreme
Court of Pennsylvania, where they lost. Id. at 494–95. Left
with plans for a casino but no slot machines, the partnership
instead chose a new venture: Chapter 11 bankruptcy. Id. at 495.

-- 15 of 20 --

16
There, the trustee for the debtor partnership filed an
adversary complaint against the Commonwealth, seeking—
under the applicable provisions of the Bankruptcy Code—to
avoid the transfer of the license to the Commonwealth and claw
back its $50 million value into the estate. Id. at 495–96. As
relevant here, the Bankruptcy Court, later affirmed by the
District Court, dismissed several counts of the avoidance
action as barred by Rooker-Feldman. Id. at 497–98.
We reversed. As we explained, “[b]y asking the
Bankruptcy Court to find that the license revocation was an
avoidable fraudulent transfer, the Trustee did not invite that
Court to ‘review and reject’ the [state-court] revocation order.”
Id. at 500. The issue presented to the Bankruptcy Court by the
avoidance action was not the “bona fides” of the state-court
judgment affirming the revocation, but “whether that
revocation, which occurred because of valid state proceedings,
could nonetheless be avoided under the Bankruptcy Code.” Id.
at 501. No matter the “overlapping legal issues” between the
state-court ligation and the avoidance action—the “fraudulent
transfer claim in the Bankruptcy Court was independent” of the
claims “previously advanced in the state court.” Id. at 501–02.
We endorse this focus on the independence of a
litigant’s claims as the more precise reading of Exxon Mobil,
which rejected our reliance on what we once called Rooker-
Feldman’s “‘inextricably intertwined’ bar.” 544 U.S. at 291
(quotation omitted). We defined “inextricably intertwined” for
Rooker-Feldman purposes to “mean[] that federal relief can
only be predicated upon a conviction that the state court was
wrong.” E.g., Knapper, 407 F.3d at 580 (quoting Walker v.
Horn, 385 F.3d 321, 329 (3d Cir.2004)). We hope that by now
we have explained why this definition impermissibly blurs the

-- 16 of 20 --

17
lines between Rooker-Feldman and preclusion. To repeat, a
lower federal court may not refuse to “exercis[e] subject-
matter jurisdiction simply because a party attempts to litigate
in federal court a matter previously litigated in state court.”
Exxon Mobil, 544 U.S. at 293. Those attempts, no doubt
animated by a party’s belief “that the state court was wrong,”
Knapper, 407 F.3d at 580 (quoting Walker, 385 F.3d at 329),
nonetheless require us to exercise “jurisdiction and [apply]
state law [to] determin[e] whether the defendant prevails under
principles of preclusion,” Exxon Mobil, 544 U.S. at 293
(quotation omitted).4
4 Along with Knapper, our 2009 decision in In re Madera, 586
F.3d 228 (3d Cir. 2009), applying Rooker-Feldman to dismiss
a debtor’s claims because success for the debtor “in the federal
courts would prevent the [state court] from enforcing its order
to foreclose the mortgage,” id. at 232, was decided without the
benefit of Great Western Mining & Mineral Company v. Fox
Rothschild LLP, 615 F.3d 159 (3d Cir. 2010). In Great Western
Mining, through the incisive majority opinion by our colleague
Judge Fuentes, we refined—and narrowed—our view of the
doctrine after Exxon Mobil. We explained at length that a
federal plaintiff who brings a claim “independent” of a state-
court judgment does not defy Rooker-Feldman, even if the
plaintiff seeks relief that would somehow frustrate a state-court
judgment. Id. at 163–73. Because that kind of “independent”
claim does not invite a review of the state-court judgment, but
asserts a claim premised on “some other source of injury,” it
does not pose the jurisdictional problems Rooker-Feldman
guards against. Id. at 167–68 (quotation omitted).

-- 17 of 20 --

18
C. Rooker-Feldman does not prohibit jurisdiction over
Adams’s claims, but they are precluded under New
Jersey law.
Because Adams is not a federal plaintiff, Rooker-
Feldman does not apply to bar jurisdiction. We instead rule that
Adams’s claims are precluded.
At first look, Adams’s claims would seem to fall within
Rooker-Feldman’s ambit. No doubt she has, in reality,
“repaired to federal court to undo the [New Jersey] judgment
in [Nationstar’s] favor.” Id. at 293. Before us, she disputes the
application of Rooker-Feldman but otherwise relitigates the
state-court foreclosure proceedings, claiming the whole case
was based on a “big lie [that] was adopted by the Bankruptcy
Court and the District Court.” Opening Br. 19.
But Adams is no Rooker-Feldman plaintiff. She is not
even a movant. Nationstar held a foreclosure judgment in its
favor. That makes it a “party in interest” to Adams’s
bankruptcy estate, as a holder of a judgment against the estate’s
property, the house. 11 U.S.C. §§ 362(a)(2), 362(d). So
Nationstar moved for relief from the automatic stay. Id. §
362(d). Opposing Nationstar’s motion, Adams argued—as she
does here—that the New Jersey judgment was wrongly
decided, as neither Nationstar nor EverBank held the
mortgage.
That claim is precluded.5 We give the New Jersey
foreclosure judgment the same preclusive force New Jersey
5 Wrapped up in this claim are several issues—the validity of
the mortgage’s assignment, the banks’ standing to foreclose,

-- 18 of 20 --

19
courts would. 28 U.S.C. § 1738. Thus, applying New Jersey
law, her claims are precluded if the foreclosure judgment was
“valid, final, and on the merits”; (2) the parties in the later
action are identical to, or in privity with, those in the prior
action; and (3) her claim in this “later action” stems from the
“same transaction or occurrence as the claim in the earlier”
foreclosure action. Watkins v. Resorts Int’l Hotel & Casino,
Inc., 591 A.2d 592, 599 (1991).
In that analytical context, our conclusion follows easily.
The state-court foreclosure judgment was valid, final, and
reached the merits. As EverBank could litigate the foreclosure
without substituting Nationstar, those parties are in privity, if
not considered the same. N.J. Rules of Court 4:34-3. And
Adams’s claims here are nothing but reruns of her claims in
state court. She has even admitted so. App. 290 (Adams’s
counsel, arguing against Nationstar’s motion to lift the stay
before the Bankruptcy Court: “It is true that we’re attacking the
foreclosure judgment.”). Bound by the judgment for
EverBank, Adams is precluded from any attempt to secure a
different outcome in our Court.
* * *
The Rooker-Feldman doctrine is narrow, and it applies
only when a federal plaintiff improperly invokes the
jurisdiction of a district court to appeal—in fact or in effect—
a state-court judgment. That is not the case here. Eileen Adams
is not a plaintiff, but she has once more tried to litigate the
validity of the state-court foreclosure judgment against her
and on—that are issue precluded. Claim preclusion is enough
to defeat Adams’s efforts here.

-- 19 of 20 --

20
home. Even though her claims are not barred by Rooker-
Feldman, they are precluded under New Jersey law. So we
affirm the District Court’s order insofar as it affirmed the
Bankruptcy Court’s granting of Nationstar’s motion to lift the
automatic stay.

-- 20 of 20 --