Although we assume that their FDCPA classes are quite good, we report that a district court magistrate in Tennessee refused an in pro per Plaintiff’s request for an order requiring defense counsel to attend FDCPA classes at a local law school.  The case arose in Livinston-Cross v. Bank of America, 2009 WL 1471126 (M.D.Tenn. 2009), where Judge Campbell relied on the Rooker-Feldman doctrine to prohibit a Plaintiff’s federal FDCPA lawsuit challenging the manner in which the defendant and its lawyer obtained a judgment on a collection matter.  The Magistrate explained:


[A]s to the issue of the amount of the debt and the review of the state court judgment, the Magistrate Judge agrees with the Defendants that the Rooker-Feldman Doctrine also applies. As such, this Court does not have jurisdiction over this issue. The Plaintiff initiated this action in federal court complaining of injury caused by a state court judgment and seeking a review and rejection of that judgment. In Re Cook, 551 F.3d 542, 548 (6th Cir.2009).FN2 The pertinent question in determining whether a federal district court is precluded under the Rooker-Feldman doctrine from exercising subject-matter jurisdiction over a claim is “whether the ‘source of the injury’ upon which plaintiff bases his federal claim is the state court judgment.” Id. citing Lawrence v. Welch, 531, F3d, 364, 368 (6th Cir.2008). This is clearly the case in the instant action as the Plaintiff requests that this Court find that the amount of the state court judgment is incorrect. As such, this Court is precluded from reviewing this portion of Plaintiffs complaint.



Accordingly, the District Court denied Plaintiff’s requested relief, including Plaintiff’s request for an “order the [defense] lawyers to attend FDCPA classes at Nashville School of Law”.