WATSON v. Mutual of Omaha Bank; Old Republic National Title Insurance Company Defendants - Appellees (2019)

[Unpublished]

Robert Watson challenged the foreclosure of his home in federal court. He alleges that various state-court orders violated his equal-protection rights and, separately, that Old Republic National Title Insurance breached a title-insurance policy by failing to make an insurance payment to Mutual of Omaha Bank. The district court ¹ dismissed both claims.

The district court lacked jurisdiction under the Rooker-Feldman doctrine to consider Watson’s equal-protection claim. See Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284, 125 S.Ct. 1517, 161 L.Ed.2d 454 (2005) (“The Rooker-Feldman doctrine ․ [applies to] cases 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.”). Federal courts have no authority to “quash” state-court judgments, which is what Watson asked the district court to do. See Skit Int’l, Ltd. v. DAC Techs. of Ark., Inc., 487 F.3d 1154, 1157 (8th Cir. 2007) (describing a “classic illustration” of an appeal covered by the Rooker-Feldman doctrine).

The district court also properly dismissed Watson’s breach-of-contract claim. When a state-law claim is brought in federal court, the plaintiff must meet both Article III and state standing requirements. See Myers v. Richland County, 429 F.3d 740, 749 (8th Cir. 2005). Under Nebraska law, a plaintiff like Watson may not sue for breach of contract without being either a party or an intended third-party beneficiary of the contract. See Marten v. Staab, 249 Neb. 299, 543 N.W.2d 436, 441–42 (1996). We agree with the district court that Watson was, at most, an incidental beneficiary who had no standing to sue. See Palmer v. Lakeside Wellness Ctr., 281 Neb. 780, 798 N.W.2d 845, 850 (2011) (discussing the requirements for enforcing a contract as a third-party beneficiary); Spring Valley IV Joint Venture v. Neb. State Bank of Omaha, 269 Neb. 82, 690 N.W.2d 778, 782–83 (2005) (dismissing a breach-of-contract claim for lack of standing because the claimant was only an incidental beneficiary).

The judgment of the district court is affirmed. See 8th Cir. R. 47B.

FOOTNOTES

1.   The Honorable Robert F. Rossiter, Jr., United States District Judge for the District of Nebraska.

PER CURIAM.