On May 8, 2008, the Court of Appeals for the Ninth Circuit in Reusser v. Wachovia Bank, __ F.3d __ (9th Cir. 2008) applied the Rooker-Feldman doctrine to bar re-litigation in federal court of the propriety of a non-judicial foreclosure that had been stayed by the consumer’s bankruptcy.  The Rooker-Feldman doctrine holds that federal courts lack jurisdiction to review claims seeking review of a state court judgment, as well as cases “inevitably intertwined” with a prior state court judgment.  District of Colombia Court of Appeals v. Feldman, 460 U.S. 462 (1983); Rooker v. Fidelity Trust, 263 U.S. 413 (1923).   In Reusser, the Court of Appeals invoked the Rooker-Feldman doctrine to bar a section 1983 claim seeking review of a foreclosure on a consumer’s home, finding it inextricably intertwined with a state court’s decision such that adjudication of the federal claim would undercut a state court ruling or require a district court to interpret application of state laws or procedural rules.  Applicable to FDCPA claims, a federal court may lack jurisdiction of an FDCPA claim where the claim seeks to adjudicate the manner in which an underlying judgment on a collection action was obtained.  The Court of Appeals cited, but did not discuss or distinguish, Kougasian v. TMSL, Inc. 359 F.3d 1136 (9th Cir. 2004) which held that the Rooker-Feldman doctrine did not bar a state court judgment obtained by extrinsic fraud of a party.  reusser-v-wachovia-bank-na-__-f3d-__-9th-cir-2008