A district judge in the Northern District of Illinois has awarded sanctions to several banks who were sued in a federal case arising out of a state court foreclosure judgment. Plaintiff lost the state case and the state court entered a judgment of foreclosure in favor of banks who held mortgage liens on the property.
Because the state court issued a final judgment adverse to plaintiffs, plaintiffs’ counsel violated Rule 11 by filing a federal action to stop the foreclosure. Plaintiffs should have known their legal position was frivolous because federal courts in such cases, abstain from proceeding under the Rooker-Feldman doctrine. Plaintiffs’ counsel was sanctioned in the amount of $20,000.