Iqbal v. Patel

Iqbal bought a gasoline service station and contracted with S-Mart Petroleum for gasoline. Iqbal then hired Patel to conduct the business, ceding operational control to him. He chose Patel on the recommendation of Johnson, S-Mart’s president. Patel ran the business but did not pay for the gasoline, leading S-Mart to sue. The Indiana state court entered a judgment of more than $65,000 against Iqbal as guarantor. Under a settlement, Iqbal gave S-Mart a note, secured by a mortgage on the business premises. When he still did not pay, a state court entered a second judgment against him, and the property was sold in a foreclosure auction. Iqbal filed a federal suit, alleging that Patel and Johnson acted in cahoots to defraud him out of his business and seeking treble damages under 18 U.S.C. 1964, the Racketeer Influenced and Corrupt Organizations Act (RICO). The district court dismissed the complaint as barred by the Rooker-Feldman doctrine because it challenged the state court’s judgments. The Seventh Circuit reversed, reasoning that Iqbal seeks damages for activity that (he alleges) predated the state litigation and caused injury independently of it. View "Iqbal v. Patel" on Justia Law