In Parker v. Potter, the United States Court of Appeals for the Eleventh Circuit has held that the Rooker-Feldman doctrine bars a district court from hearing a rescission claim under the Truth in Lending Act (TILA)
Plaintiff Yolanda Parker’s husband, Gary, refinanced his Clearwater, Florida home with Money Consultants, Inc., which immediately assigned the note and mortgage to Defendant Nancy Potter. Gary subsequently quit-claimed the home to himself and Yolanda. A short while later, Potter proceeded with foreclosure proceedings which, after Yolanda failed to have them restrained by court order, concluded with a Florida court entering a judgment of foreclosure against Gary and Yolanda Parker. Approximately nine months later, Yolanda sent a letter to Potter stating her intent to rescind the foreclosed mortgage under TILA. Potter nonetheless pursued a foreclosure sale, at which she purchased the property, then subsequently sold to a third party.