Mortgage Servicing and Loan Modifications: 11.7.5.4.2 Where federal defendants were not parties to the state court action
Some courts have suggested that if the federal defendants were not parties to the state court proceedings, this may be a reason not to apply the Rooker-Feldman doctrine even though the federal plaintiff was a party.546 The Tenth Circuit has held that merely adding defendants beyond those involved in the state court case does not avoid th